Schaefer v. Commissioner
United States Tax Court
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
- Mistretta v. United StatesSupreme Court of the United States · 1989
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
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