Bolton v. Commissioner
United States Tax Court
Petitioners in 1976 owned a vacation home which was rented for 91 days, used for personal purposes for 30 days, and left vacant for the remainder of the year.
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Petitioners in 1976 owned a vacation home which was rented for 91 days, used for personal purposes for 30 days, and left vacant for the remainder of the year. Held, in applying the limitation on deductions of rental expenses in sec. 280A(c)(5)(B), I.R.C. 1954, petitioners correctly allocated 25 percent of the interest and property taxes paid with respect to the vacation home to its rental use, corresponding to the approximate percentage of the days of the year the property was rented.
1Opinion of the Court
Dorance D. Bolton and Helen A. Bolton, Petitioners v. Commissioner of Internal Revenue, Respondent
Bolton v. Commissioner
Docket No. 7741-79
United States Tax Court
77 T.C. 104; 1981 U.S. Tax Ct. LEXIS 95;
July 27, 1981, Filed
Decision will be entered under Rule 155.
Petitioners in 1976 owned a vacation home which was rented for 91 days, used for personal purposes for 30 days, and left vacant for the remainder of the year. Held, in applying the limitation on deductions of rental expenses in sec. 280A(c)(5)(B), I.R.C. 1954, petitioners correctly allocated 25 percent of the interest and property taxes…
2Cases cited2 opinions
- Bolton v. CommissionerUnited States Tax Court · 1981
- McKinney v. CommissionerUnited States Tax Court · 1981