Legal Opinion

Hooper v. Commissioner

United States Tax Court

Decided June 27, 1974No. Docket No. 5822-71UnpublishedCited by 1 opinion

Held: Petitioners are not entitled to deduct losses on their joint income tax returns arising from the operation of petitioner William James Hooper's wholly-owned business, the Nu-Idea Corporation, since a proper subchapter S election was not in effect during the years in issue.

1Opinion of the Court

WILLIAM JAMES HOOPER and GWENDOLYN RILEY HOOPER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hooper v. Commissioner

Docket No. 5822-71

United States Tax Court

T.C. Memo 1974-176; 1974 Tax Ct. Memo LEXIS 142; 33 T.C.M. (CCH) 759; T.C.M. (RIA) 74176;

June 27, 1974, Filed.

Held: Petitioners are not entitled to deduct losses on their joint income tax returns arising from the operation of petitioner William James Hooper's wholly-owned business, the Nu-Idea Corporation, since a proper subchapter S election was not in effect during the years in issue.

William James Hooper, Pro Se.

J. Leon…

2Cases cited10 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Koshland v. HelveringSupreme Court of the United States · 1936
  4. Casey v. CommissionerUnited States Tax Court · 1962
  5. Langdon L. Skarda, Carolyn A. Skarda, Lynell G. Skarda, Kathryn B. Skarda, Cash T. Skarda and Annabel S. Skarda v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1957

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3Cited by1 opinion

  1. Smith S, Inc. v. CommissionerDistrict Court, E.D. North Carolina · 1993

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