Legal Opinion
Daniel E. Larkin & Christine L. Larkin v. Commissioner
United States Tax Court
Decided May 28, 2020No. 6345-14Unpublished
1Opinion of the Court
T.C. Memo. 2020-70
UNITED STATES TAX COURT DANIEL E. LARKIN AND CHRISTINE L. LARKIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6345-14. Filed May 28, 2020. In 2008, 2009, and 2010 Ps, an attorney and a homemaker who were U.S. nonresident citizens, owned interests in various entities and real properties in the United States and Europe. Ps’ joint Federal income tax returns for 2008, 2009, and 2010 claimed Schedule A deductions, Schedule E losses, self-employed health insurance deductions, and foreign tax credits. By notice of deficiency issued in 2013, R disallowed…
2Cases cited33 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Zenith Radio Corp. v. Hazeltine Research, Inc.Supreme Court of the United States · 1971
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
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