Legal Opinion
Michael F. Connor and Jane H. Connor v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided July 5, 2000No. 99-3324PublishedCited by 13 opinions
1Opinion of the Court
KANNE, Circuit Judge.
Michael and Jane Connor appeal a tax court decision finding a deficiency of $3,616 in their 1993 federal income tax and $6,089 in their 1994 federal income tax. This finding of deficiency arose from the determination that Michael Connor actively managed his personal services C corporation, which rents an office building owned by Jane Connor, and for this reason, the passive activity loss rules barred the offset of income from the rental against other passive losses. The Connors claim on appeal that in 1993 and 1994 the “material participation” requirement of the passive…
2Cases cited14 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Stinson v. United StatesSupreme Court of the United States · 1993
- Keppel v. Tiffin Savings BankSupreme Court of the United States · 1905
- United States v. Jeffrey Szakacs, Daniel Spanley, John M. Neff, Tyrone Noble and Brian BaloskiCourt of Appeals for the Seventh Circuit · 2000
- James A. Pittman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
9 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Operating Engineers Local 139 Health Benefit Fund v. Gustafson Construction CorporationCourt of Appeals for the Seventh Circuit · 2001
- David and Lynette Kindred v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
- Sidell v. CommissionerCourt of Appeals for the First Circuit · 2000
- Thomas P. Krukowski and Ermina A. Krukowski v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2002
- Carlos v. Comm'rUnited States Tax Court · 2004
8 more not listed; retrieve them via the Exa API.