Broz v. Comm'r
United States Tax Court
Ps were shareholders in a wholly owned S corporation (S) engaged in providing wireless cellular service. S acquired wireless cellular licenses from the FCC and built networks to service the license areas. S never operated any on-air networks. Instead, P formed related holding companies to hold title to the licenses and equipment. Many issues raised questions of first impression because transactions were structured in this ever-changing technology industry.
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Ps were shareholders in a wholly owned S corporation (S) engaged in providing wireless cellular service. S acquired wireless cellular licenses from the FCC and built networks to service the license areas. S never operated any on-air networks. Instead, P formed related holding companies to hold title to the licenses and equipment. Many issues raised questions of first impression because transactions were structured in this ever-changing technology industry. Our holdings on these issues include: 1. Held: Ps were not sufficiently at risk for sec. 465, I.R.C., purposes when stock of a related…
1Opinion of the Court
Kroupa, Judge:
Respondent determined over $16 million of deficiencies1 in petitioners’ Federal income tax for 1996, 1998, 1999, 2000 and 2001 (years at issue). Respondent also determined that petitioners were liable for accuracy-related penalties of $563,042 for 1998, $386,489 for 1999, and $591,213 for 2000.
After concessions,2 we are asked to decide several issues, many of which present questions of first impression as they relate to the ever-evolving cellular phone industry. We must first decide a procedural issue, whether respondent is bound by equitable estoppel to a settlement offer made…
2Cases cited47 opinions
- Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
- Lexecon Inc. v. Milberg Weiss Bershad Hynes & LerachSupreme Court of the United States · 1998
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Putnam v. CommissionerSupreme Court of the United States · 1956
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3Cited by11 opinions
- Broz v. CommissionerCourt of Appeals for the Sixth Circuit · 2013
- Hewlett-Packard Co. v. Comm'rUnited States Tax Court · 2012
- Robert F Broz v. Plante & Moran PllcMichigan Court of Appeals · 2018
- Suriel v. CommissionerUnited States Tax Court · 2013
- Broz v. Comm'rUnited States Tax Court · 2011
6 more not listed; retrieve them via the Exa API.