Cabintaxi Corp. v. Commissioner
United States Tax Court
R issued notices of final S corporation administrative adjustment (FSAA) to CT for its 1984 and 1985 tax years. R determined that CT's S corporation election was invalid because not all of CT's shareholders consented to the election. Additionally, R disallowed CT's claimed deductions under secs. 162(a), 195, and 248, I.R.C., for 1984 and 1985. Held: CT's S corporation election was invalid because not all of CT's shareholders consented to the election.
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R issued notices of final S corporation administrative adjustment (FSAA) to CT for its 1984 and 1985 tax years. R determined that CT's S corporation election was invalid because not all of CT's shareholders consented to the election. Additionally, R disallowed CT's claimed deductions under secs. 162(a), 195, and 248, I.R.C., for 1984 and 1985. Held: CT's S corporation election was invalid because not all of CT's shareholders consented to the election. Held, further, CT is not entitled to its claimed deductions for 1984 and 1985, because CT was not carrying on a trade or business in those…
1Opinion of the Court
CABINTAXI CORPORATION, F.K.A. AUTOMATED TRANSIT, INC., ROBERT W. EDLER, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cabintaxi Corp. v. Commissioner
Docket No. 27539-92
United States Tax Court
T.C. Memo 1994-316; 1994 Tax Ct. Memo LEXIS 323; 68 T.C.M. (CCH) 49;
July 11, 1994, Filed
Decision will be entered for respondent.
R issued notices of final S corporation administrative adjustment (FSAA) to CT for its 1984 and 1985 tax years. R determined that CT's S corporation election was invalid because not all of CT's shareholders consented to the election. Additionally,…
2Cases cited13 opinions
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Richmond Television Corp. v. United StatesSupreme Court of the United States · 1965
- Madison Gas and Electric Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1980
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
8 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Cabintaxi Corporation, Formerly Known as Automated Transit, Incorporated, and Robert Edler, "Tax Matters Person," v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1995