Taproot Admin. Servs. v. Comm'r
United States Tax Court
R determined that P is ineligible for S corporation status in 2003 because its shareholder was a Roth individual retirement account (Roth IRA). As a consequence, R determined that P is taxable as a C corporation for 2003. Held: The Roth IRA is not an eligible S corporation shareholder. P is taxable as a C corporation for 2003.
1Opinion of the Court
OPINION
Wherry, Judge:
This case, which involves a petition for redetermination of a deficiency for petitioner’s 2003 tax year, is before the Court on respondent’s October 23, 2008, motion for partial summary judgment. See Rule 121(a).1 Respondent argues that petitioner is not eligible for S corporation status during 2003 because it had an ineligible shareholder — a Roth individual retirement account (Roth ira) — during that year. Petitioner counters that a Roth IRA is an eligible S corporation shareholder and that petitioner’s S corporation status remained intact. For the reasons discussed…
2Cases cited28 opinions
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- United States v. Philadelphia National BankSupreme Court of the United States · 1963
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
23 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Taproot Administrative Services, Inc. v. CommissionerCourt of Appeals for the Ninth Circuit · 2012
- AmerGen Energy Co. ex rel. Exelon Generation Co. v. United StatesUnited States Court of Federal Claims · 2010
- Paschall v. CommissionerUnited States Tax Court · 2011
- CNT Investors, LLC v. Comm'rUnited States Tax Court · 2015
- Corbalis v. Comm'rUnited States Tax Court · 2014
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