Casel v. Commissioner
United States Tax Court
Held, sec. 1.267(b)-1(b)(1) and (2), Income Tax Regs., which, in part, provides that a transaction described in sec. 267(a), I.R.C. 1954, between a partnership and a person other than a partner shall be considered as occurring between the other person and the members of the partnership separately, is valid.
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Held, sec. 1.267(b)-1(b)(1) and (2), Income Tax Regs., which, in part, provides that a transaction described in sec. 267(a), I.R.C. 1954, between a partnership and a person other than a partner shall be considered as occurring between the other person and the members of the partnership separately, is valid. Held, further, petitioners may not deduct taxes and interest paid with respect to real estate to the extent that such taxes and interest accrued prior to the date that taxpayers acquired an interest in the property.
1Opinion of the Court
Edward Casel and Janice G. Casel, Petitioners v. Commissioner of Internal Revenue, Respondent
Casel v. Commissioner
Docket No. 11025-79
United States Tax Court
79 T.C. 424; 1982 U.S. Tax Ct. LEXIS 44; 79 T.C. No. 26;
September 1, 1982, Filed
Decision will be entered for the respondent.
Held, sec. 1.267(b)-1(b)(1) and (2), Income Tax Regs., which, in part, provides that a transaction described in sec. 267(a), I.R.C. 1954, between a partnership and a person other than a partner shall be considered as occurring between the other person and the members of the partnership separately, is valid. Held,…
2Cases cited18 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
- World Airways, Inc. v. CommissionerUnited States Tax Court · 1974
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