Moss v. Commissioner
United States Tax Court
Petitioners are the owners of a hotel through their respective partnership interests. The hotel was leased to another partnership who, in turn, subleased the property for management purposes. Prior to the taxable year in issue, the sublessee of the hotel and its guarantor suffered financial difficulties. Substantial repairs, maintenance and capital improvements were not performed on the hotel for several years.
Read the full summary
Petitioners are the owners of a hotel through their respective partnership interests. The hotel was leased to another partnership who, in turn, subleased the property for management purposes. Prior to the taxable year in issue, the sublessee of the hotel and its guarantor suffered financial difficulties. Substantial repairs, maintenance and capital improvements were not performed on the hotel for several years. The guarantor was released from its obligations and petitioners entered into a new agreement with respect to the hotel's management. Incorporated directly within the new management…
1Opinion of the Court
JEROME S. MOSS AND SANDRA MOSS, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Moss v. Commissioner
Docket Nos. 5571-82, 5572-82, 5573-82.
United States Tax Court
T.C. Memo 1986-128; 1986 Tax Ct. Memo LEXIS 480; 51 T.C.M. (CCH) 742; T.C.M. (RIA) 86128;
March 31, 1986; REVERSED October 28, 1987
Petitioners are the owners of a hotel through their respective partnership interests. The hotel was leased to another partnership who, in turn, subleased the property for management purposes. Prior to the taxable year in issue, the sublessee of the hotel and its guarantor suffered…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Illinois Merchants Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Joseph Merrick Jones and Eugenie Penick Jones v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Oberman Mfg. Co. v. CommissionerUnited States Tax Court · 1967
- Plainfield-Union Water Co. v. Comm'rUnited States Tax Court · 1962
9 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Jerome S. Moss, Sandra Moss, Sharon M. Alesia, Herb Alpert, and Lani Alpert v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987