Legal Opinion

Inness v. Commissioner

United States Tax Court

Decided June 19, 1968No. Docket Nos. 2076-64, 2102-64, 5572-64UnpublishedCited by 1 opinion

Held, that the income derived from and expenses incurred in a potato-growing-and-selling business were attributable to and reportable by Bob Inness Co. of Montana, Inc., rather than by petitioner Bob Inness Co., a proprietorship electing to be taxed as a corporation under sec. 1361, I.R.C. 1954. [Net operating loss deduction was disallowed.] Held, further, that the advances by petitioner Bob Inness Co. to or on behalf of Bob Inness Co. of Montana, Inc., during 1960, 1961,…

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Held, that the income derived from and expenses incurred in a potato-growing-and-selling business were attributable to and reportable by Bob Inness Co. of Montana, Inc., rather than by petitioner Bob Inness Co., a proprietorship electing to be taxed as a corporation under sec. 1361, I.R.C. 1954. [Net operating loss deduction was disallowed.] Held, further, that the advances by petitioner Bob Inness Co. to or on behalf of Bob Inness Co. of Montana, Inc., during 1960, 1961, and 1962 were contributions to capital rather than loans. Held, further, that assessment and collection of the…

1Opinion of the Court

Robert J. Inness and Yvette Inness v. Commissioner. Bob Inness Company v. Commissioner.

Inness v. Commissioner

Docket Nos. 2076-64, 2102-64, 5572-64.

United States Tax Court

T.C. Memo 1968-120; 1968 Tax Ct. Memo LEXIS 178; 27 T.C.M. (CCH) 567; T.C.M. (RIA) 68120;

June 19, 1968. Filed

Held, that the income derived from and expenses incurred in a potato-growing-and-selling business were attributable to and reportable by Bob Inness Co. of Montana, Inc., rather than by petitioner Bob Inness Co., a proprietorship electing to be taxed as a corporation under sec. 1361, I.R.C. 1954. [Net operating loss…

2Cases cited10 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  3. Nassau Lens Co., Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Harry Pildes and Sarah PildesCourt of Appeals for the Second Circuit · 1962
  4. Commissioner of Int. Rev. v. Meridian & Thirteenth R. Co.Court of Appeals for the Seventh Circuit · 1942
  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. Robert J. Inness, Yvette Inness, and Bob Inness Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969

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