Legal Opinion

Schaefer v. Commissioner

United States Tax Court

Decided September 13, 1995No. Docket No. 6555-94Published

Sec. 1.469-2T(c)(7)(iv), Temporary Income Tax Regs., provides that passive activity gross income does not include "Gross income of an individual from a covenant by such individual not to compete". Held, the regulation is valid.

1Opinion of the Court

WILLIAM H. SCHAEFER, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Schaefer v. Commissioner

Docket No. 6555-94.

United States Tax Court

105 T.C. 227; 1995 U.S. Tax Ct. LEXIS 51; 105 T.C. No. 16;

September 13, 1995, Filed

Decision will be entered for respondent.

Sec. 1.469-2T(c)(7)(iv), Temporary Income Tax Regs., provides that passive activity gross income does not include "Gross income of an individual from a covenant by such individual not to compete".

Held, the regulation is valid.

Allen L. Schwait, for petitioner.

Helen F. Rogers, for respondent.

RAUM, Judge

RAUM

OPINION

RAUM, Judge:…

2Cases cited17 opinions

  1. Mistretta v. United StatesSupreme Court of the United States · 1989
  2. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  3. United States v. CorrellSupreme Court of the United States · 1967
  4. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
  5. Rowan Cos. v. United StatesSupreme Court of the United States · 1981

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