Kuhn v. Commissioner
United States Tax Court
P leased certain property to his controlled corporation at a rate assumed, arguendo, to be below market. P made no substantial personal use of the property, nor was such personal use a consideration at the time of purchase or thereafter. Held: P had a profit objective, within the meaning of sec. 183, I.R.C. P's objective was to achieve an economic profit, whether such profit was earned individually or through the corporation.
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P leased certain property to his controlled corporation at a rate assumed, arguendo, to be below market. P made no substantial personal use of the property, nor was such personal use a consideration at the time of purchase or thereafter. Held: P had a profit objective, within the meaning of sec. 183, I.R.C. P's objective was to achieve an economic profit, whether such profit was earned individually or through the corporation. Held, further, with respect to conceded understatements unrelated to the profit-objective issue, Ps are liable for the substantial understatement addition, imposed by…
1Opinion of the Court
WILLIAM J. KUHN, JR. AND ESTATE OF HELEN M. KUHN, DECEASED, WILLIAM J. KUHN, JR., EXECUTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kuhn v. Commissioner
Docket No. 4169-90
United States Tax Court
T.C. Memo 1992-460; 1992 Tax Ct. Memo LEXIS 483; 64 T.C.M. (CCH) 488;
August 13, 1992, Filed
Decision will be entered under Rule 155.
P leased certain property to his controlled corporation at a rate assumed, arguendo, to be below market. P made no substantial personal use of the property, nor was such personal use a consideration at the time of purchase or thereafter.
Held: P had a…
2Cases cited6 opinions
- Dreicer v. CommissionerUnited States Tax Court · 1982
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
- Estate of Baron v. CommissionerUnited States Tax Court · 1984
- Estate of Sydney S. Baron, Sylvia S. Baron, Administratrix, and Sylvia S. Baron v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Morton v. United StatesUnited States Court of Federal Claims · 2011