Rosenberg v. Commissioner
United States Tax Court
A corporation constructed a 15-unit condominium building in 1979, sold one unit in 1981, and rented other units until 1984. The corporation reported its income and expenses, including carrying charges of interest and taxes, under subch. C of the Code through its fiscal year ended Nov. 30, 1982, when a subch. S election was made. This election was in effect in 1984 when 13 of the remaining condominium units were sold.
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A corporation constructed a 15-unit condominium building in 1979, sold one unit in 1981, and rented other units until 1984. The corporation reported its income and expenses, including carrying charges of interest and taxes, under subch. C of the Code through its fiscal year ended Nov. 30, 1982, when a subch. S election was made. This election was in effect in 1984 when 13 of the remaining condominium units were sold. Held, the carrying charges included in the net operating losses incurred while the corporation was in subch. C status may not offset 1984 income of the S corporation passed…
1Opinion of the Court
Alex Rosenberg and Bertha Rosenberg, Petitioners v. Commissioner of Internal Revenue, Respondent
Rosenberg v. Commissioner
Docket No. 12777-88
United States Tax Court
96 T.C. 451; 1991 U.S. Tax Ct. LEXIS 18; 96 T.C. No. 15;
March 7, 1991, Filed
Decision will be entered for the respondent.
A corporation constructed a 15-unit condominium building in 1979, sold one unit in 1981, and rented other units until 1984. The corporation reported its income and expenses, including carrying charges of interest and taxes, under subch. C of the Code through its fiscal year ended Nov. 30, 1982, when a subch. S…
2Cases cited10 opinions
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
- Fred E. Hudspeth v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1990
- Capitol Coal Corp. v. CommissionerUnited States Tax Court · 1956
- Capitol Coal Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Home Mutual Insurance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Seventh Circuit · 1980
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