Osborne v. Commissioner
United States Tax Court
The corporation in which petitioners were equal shareholders received rents during its taxable years ended May 31, 1960 and 1961, in excess of 20 percent of its gross receipts for such years.
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The corporation in which petitioners were equal shareholders received rents during its taxable years ended May 31, 1960 and 1961, in excess of 20 percent of its gross receipts for such years. Held, that the corporation's election to be treated as a small business corporation under subchapter S of the Internal Revenue Code of 1954 was terminated for its taxable year ended May 31, 1960, and for its succeeding taxable years under sec. 1372(e)(5) of the Code; that sec. 1372(e)(5) as amended by Pub. L. 89-389, 80 Stat. 111 (Apr. 14, 1966), has no bearing on years beginning before Jan. 1, 1963; and…
1Opinion of the Court
Weldon F. Osborne and Eleanor W. Osborne, Petitioners v. Commissioner of Internal Revenue, Respondent
Osborne v. Commissioner
Docket No. 2376-65
United States Tax Court
55 T.C. 329; 1970 U.S. Tax Ct. LEXIS 27;
November 24, 1970, Filed
Decision will be entered under Rule 50.
The corporation in which petitioners were equal shareholders received rents during its taxable years ended May 31, 1960 and 1961, in excess of 20 percent of its gross receipts for such years. Held, that the corporation's election to be treated as a small business corporation under subchapter S of the Internal Revenue Code of 1954…
2Cases cited1 opinion
- Osborne v. CommissionerUnited States Tax Court · 1970