Wakefield v. Comm'r
United States Tax Court
R determined deficiencies in income tax for Ps' 2002, 2003, and 2004 taxable years arising from Ps' failure to report income they received in connection with an ESOP and an S corporation, R's disallowance of deductions for passthrough losses from Ps' wholly owned partnership, and related computational adjustments.
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R determined deficiencies in income tax for Ps' 2002, 2003, and 2004 taxable years arising from Ps' failure to report income they received in connection with an ESOP and an S corporation, R's disallowance of deductions for passthrough losses from Ps' wholly owned partnership, and related computational adjustments. Before trial the parties settled outstanding issues other than Ps' entitlement todeductions for passthrough losses from their partnership, and they agreed to try the case as if Ps had directly claimed on their individual returns the deductions underlying the passthrough losses.…
1Opinion of the Court
KENNISON L. WAKEFIELD AND MARY L. WAKEFIELD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wakefield v. Comm'r
Docket No. 15383-09.
United States Tax Court
T.C. Memo 2015-4; 2015 Tax Ct. Memo LEXIS 7;
January 7, 2015, Filed
Decision will be entered under Rule 155.
R determined deficiencies in income tax for Ps' 2002, 2003, and 2004 taxable years arising from Ps' failure to report income they received in connection with an ESOP and an S corporation, R's disallowance of deductions for passthrough losses from Ps' wholly owned partnership, and related computational adjustments. Before…
2Cases cited72 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Freytag v. CommissionerSupreme Court of the United States · 1991
67 more not listed; retrieve them via the Exa API.
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