St. Charles Inv. Co. v. Commissioner
United States Tax Court
Prior to Jan. 1, 1991, X was a closely held C corporation, which incurred passive activity losses (PAL's) giving rise to suspended PAL's pursuant to sec. 469, I.R.C. A portion of the suspended PAL's was attributable to depreciation. X reduced the bases of the properties used in the passive activities by the amounts of such depreciation.
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Prior to Jan. 1, 1991, X was a closely held C corporation, which incurred passive activity losses (PAL's) giving rise to suspended PAL's pursuant to sec. 469, I.R.C. A portion of the suspended PAL's was attributable to depreciation. X reduced the bases of the properties used in the passive activities by the amounts of such depreciation. X elected S corporation status as of Jan. 1, 1991. During 1991, it disposed of several of the passive activities and calculated the gain (loss) from those dispositions using the bases of the properties involved as reduced by the depreciation. X used suspended…
1Opinion of the Court
ST. CHARLES INVESTMENT CO., BURTON C. BOOTHBY, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
St. Charles Inv. Co. v. Commissioner
Tax Ct. Dkt. No. 5793-96
United States Tax Court
110 T.C. 46; 1998 U.S. Tax Ct. LEXIS 5; 110 T.C. No. 6;
February 5, 1998, Filed
Prior to Jan. 1, 1991, X was a closely held C corporation, which incurred passive activity losses (PAL's) giving rise to suspended PAL's pursuant to sec. 469, I.R.C. A portion of the suspended PAL's was attributable to depreciation. X reduced the bases of the properties used in the passive activities by the…
2Cases cited14 opinions
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- Thomas v. PerkinsSupreme Court of the United States · 1937
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Lenz v. CommissionerUnited States Tax Court · 1993
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