Legal Opinion

Tipps v. Commissioner

United States Tax Court

Decided May 28, 1980No. Docket Nos. 8401-77, 8402-77, 7348-78, 7349-78PublishedCited by 51 opinions

Petitioner-husband's partnerships elected to deduct depreciation of expenditures to rehabilitate low-income rental housing under the accelerated method provided by sec. 167(k), I.R.C. 1954. Statements attached to the Federal income returns of each partnership for the years in issue provided all the information required for the election by sec. 1.167(k)-4(b), Income Tax Regs., except the per-unit information required by subpar. (1)(vii) and (2)(ii), thereof.

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Petitioner-husband's partnerships elected to deduct depreciation of expenditures to rehabilitate low-income rental housing under the accelerated method provided by sec. 167(k), I.R.C. 1954. Statements attached to the Federal income returns of each partnership for the years in issue provided all the information required for the election by sec. 1.167(k)-4(b), Income Tax Regs., except the per-unit information required by subpar. (1)(vii) and (2)(ii), thereof. In lieu of this information, the returns stated, "Per unit information requested by Sec. 167K. is available in our office for field…

1Opinion of the Court

Chabot, Judge:

Respondent determined deficiencies in Federal individual income tax and additions to tax under section 6653(b)2 (fraud) as follows:

Addition to tax

Docket No. Petitioner Year Deficiency sec. 6653(b)

8401-77 Judith Tipps. 1973 $90,529.92 $47,310.96

8402-77 Charles Paul

Tipps, Jr. 1973 90,529.92 47,310.96

7348-78 Charles Paul Tipps, Jr. 1970 $16,623.18 $8,311.59

1971 37,748.42 32,530.21

1972 40,906.00 20,453.00

7349-78 Judith Tipps. 1970 16,623.18 8,311.59

1971 37,748.42 32,530.21

1972 40,906.00 20,453.00

Petitioners claim overpayments as follows:

Docket No. Petitioner Year Overpayment

8401-77…

2Cases cited9 opinions

  1. Reisman v. CaplinSupreme Court of the United States · 1964
  2. Taylor v. CommissionerUnited States Tax Court · 1977
  3. Dougherty v. CommissionerUnited States Tax Court · 1973
  4. Columbia Iron & Metal Co. v. CommissionerUnited States Tax Court · 1973
  5. Valdes v. CommissionerUnited States Tax Court · 1973

4 more not listed; retrieve them via the Exa API.

3Cited by51 opinions

  1. Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
  2. Lucille Prussner, as of the Estate of Aileen E. Pfeifer v. United StatesCourt of Appeals for the Seventh Circuit · 1990
  3. Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
  4. Zuanich v. CommissionerUnited States Tax Court · 1981
  5. Gehl Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986

46 more not listed; retrieve them via the Exa API.

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