Kean v. Commissioner
United States Tax Court
Petitioner Murdock MacPherson was the beneficial owner of one-half of the 125 shares of Ocean Shores Bowl, Inc., stock issued to his brother, petitioner William MacPherson. Murdock's failure to file a consent to the subch. S election filed by Ocean Shores Bowl, Inc., invalidated the election.
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Petitioner Murdock MacPherson was the beneficial owner of one-half of the 125 shares of Ocean Shores Bowl, Inc., stock issued to his brother, petitioner William MacPherson. Murdock's failure to file a consent to the subch. S election filed by Ocean Shores Bowl, Inc., invalidated the election. Held, petitioners are not entitled to deduct the amounts claimed on their 1962 and 1963 income tax returns under sec. 1374(a), I.R.C. 1954, as their prorata shares of the net operating losses incurred by Ocean Shores Bowl, Inc., for the short taxable year 1962 and the taxable year 1963. Held, further,…
1Opinion of the Court
Fax, Judge-.
Respondent determined deficiencies in the Federal income taxes of petitioners as follows:
1962 1963 1964
1306-67_Harold G. Kean and Margaret I. Kean_._-__$26,003.90 $5,835.77 .
1341-67.Murdock D. and Mary Ellen MacPherson. 2,442.87 $2,005.56
1342-67.G. E. Milam and Verda Milam. 671.42 6,993.00 3,783.16
1343-67.Inga L. Bardahl. 1,074.72 4,200.67 .
1344-67.Ole Bardahl. 1,081.02 4,200.67 .
1362-67.William R. MacPherson and Dorothy L. MacPherson_ 1,435.98 5,365.03 .
By joint motion of the parties at the time of trial herein, these dockets were consolidated for consideration. All issues in all…
2Cases cited2 opinions
- Pestcoe v. CommissionerUnited States Tax Court · 1963
- Forrester v. CommissionerUnited States Tax Court · 1968
3Cited by78 opinions
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
- Haft Trust v. CommissionerUnited States Tax Court · 1974
- Kean v. CommissionerCourt of Appeals for the Ninth Circuit · 1972
- Danenberg v. CommissionerUnited States Tax Court · 1979
- Pacific Coast Music Jobbers, Inc. v. CommissionerUnited States Tax Court · 1971
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