Patel v. Comm'r
United States Tax Court
At the end of May 2006, Ps purchased property in Vienna, Virginia (Vienna property), with the intention to demolish the house situated thereon (house) and construct a new one on the site. Their realtor told them about the Fairfax County Fire and Rescue Department (FCFRD) Acquired Structures Program, where a property owner allows FCFRD to conduct live fire training exercises on his or her property.
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At the end of May 2006, Ps purchased property in Vienna, Virginia (Vienna property), with the intention to demolish the house situated thereon (house) and construct a new one on the site. Their realtor told them about the Fairfax County Fire and Rescue Department (FCFRD) Acquired Structures Program, where a property owner allows FCFRD to conduct live fire training exercises on his or her property. As part of the exercises, FCFRD destroys, by burning, the designated building on the owner's property. Within a few weeks of purchasing the Vienna property, Ps contacted FCFRD and obtained…
1Opinion of the Court
OPINION
Dawson, Judge:
Petitioners petitioned the Court for redetermination of a deficiency of $32,672 in their Federal income tax for 2006 and an accuracy-related penalty of $6,534.40 under section 6662.1 This case is before us on respondent’s motion for partial summary judgment pursuant to Rule 121 filed on July 19, 2011. Petitioners object to the motion and filed a response. Summary judgment may be granted with respect to all or any part of the legal issues in controversy “if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with…
2Cases cited144 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Aquilino v. United StatesSupreme Court of the United States · 1960
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
139 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- DJB Holding Corp. v. CommissionerCourt of Appeals for the Ninth Circuit · 2015
- Maines v. Comm'rUnited States Tax Court · 2015
- Mann v. United StatesDistrict Court, D. Maryland · 2019
- Bedrosian v. Comm'rUnited States Tax Court · 2014
- Bedrosian v. Comm'rUnited States Tax Court · 2014
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