Kelley v. Commissioner
United States Tax Court
Held: One petitioner, as an individual and as a transferee, is liable for additions to tax under section 6653(b). Held further: Statute of limitations is open for years at issue. Held further: Bonus constitutes taxable income in 1981 to individual petitioners. Held further: Individual petitioners may not deduct partnership loss on their 1981 return.
1Opinion of the Court
JAY R. KELLEY AND GAIL B. KELLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JAY R. KELLEY (AS TRANSFEREE OF INSULATION CONTRACTORS, INC.), Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kelley v. Commissioner
Docket Nos. 23020-88, 32292-88
United States Tax Court
T.C. Memo 1991-324; 1991 Tax Ct. Memo LEXIS 373; 62 T.C.M. (CCH) 136; T.C.M. (RIA) 91324;
July 16, 1991, Filed
Decisions will be entered under Rule 155.
Held: One petitioner, as an individual and as a transferee, is liable for additions to tax under section 6653(b). Held further: Statute of limitations is open…
2Cases cited27 opinions
- Holland v. United StatesSupreme Court of the United States · 1955
- Spies v. United StatesSupreme Court of the United States · 1943
- Rowlee v. CommissionerUnited States Tax Court · 1983
- Stone v. CommissionerUnited States Tax Court · 1971
- Otsuki v. CommissionerUnited States Tax Court · 1969
22 more not listed; retrieve them via the Exa API.