Freesen v. Commissioner
United States Tax Court
Freesen Equipment Co., a subch. S corporation of which petitioners are the sole shareholders, entered into several joint venture agreements with Freesen, Inc., with respect to topsoil removal activities at several mine sites. Freesen Equipment Co. subsequently purchased heavy construction equipment for performance of the agreed topsoil removal activities.
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Freesen Equipment Co., a subch. S corporation of which petitioners are the sole shareholders, entered into several joint venture agreements with Freesen, Inc., with respect to topsoil removal activities at several mine sites. Freesen Equipment Co. subsequently purchased heavy construction equipment for performance of the agreed topsoil removal activities. Under the terms of the joint venture agreements, Freesen, Inc., advanced Freesen Equipment Co. its share of the net profits in order to provide Freesen Equipment Co. the funds for payment of sec. 162, I.R.C. 1954, expenses. Petitioners, as…
1Opinion of the Court
Goffe, Judge'.
The commissioner determined deficiencies in petitioners’ Federal income tax as follows:
Petitioner Taxable year Amount
O. Robert Freesen 1978 $18,215.84
and Alice Freesen 1979 12,565.99
1980 3,611.84
James R. Buhlig 1978 15,795.97
and Diane Buhlig 1979 9,051.76
1980 2,627.95
Kenneth T. Cox 1978 16,635.44
and Shirley I. Cox 1979 10,500.64
1980 333.33
Eugene J. Kroencke 1978 15,631.85
and Sarah R. Kroencke 1979 7,418.28
1980 682.39
Russell M. Mosley 1978 16,005.38
and Ruth A. Mosley 1979 7,358.54
1980 640.86
Keith B. Prunty 1978 16,401.29
and Norma J. Prunty 1979 10,841.06
1980 2,628.29
Jeffrey C.…
2Cases cited13 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Helvering v. WinmillSupreme Court of the United States · 1938
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- Luna v. CommissionerUnited States Tax Court · 1964
8 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Concord Consumers Hous. Coop. v. CommissionerUnited States Tax Court · 1987
- Friendship Dairies, Inc. v. CommissionerUnited States Tax Court · 1988
- Laglia v. CommissionerUnited States Tax Court · 1987
- O. Robert Freesen v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Mearkle v. CommissionerUnited States Tax Court · 1986
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