Rojas v. Commissioner
United States Tax Court
D and E are the transferees and former majority shareholders of S, a corporation that had been engaged in the business of farming row crops. S adopted a plan of complete liquidation and pursuant to that plan, distributed to its majority shareholders all its operating assets, including certain harvested and unharvested crops.
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D and E are the transferees and former majority shareholders of S, a corporation that had been engaged in the business of farming row crops. S adopted a plan of complete liquidation and pursuant to that plan, distributed to its majority shareholders all its operating assets, including certain harvested and unharvested crops. Prior to the liquidation, S had deducted, pursuant to sec. 162(a), I.R.C. 1954, expenses incurred in connection with the cost of cultivating these crops. Held, the tax-benefit rule does not require S to include in income the expenses deducted for materials and services…
1Opinion of the Court
Dorothy Schwartz Rojas, Petitioner v. Commissioner of Internal Revenue, Respondent; Schwartz Farms, Inc., and Estate of Charles R. Schwartz, Deceased, Bank of America, National Trust and Savings Association, Administrator with the Will Annexed, Petitioners v. Commissioner of Internal Revenue, Respondent
Rojas v. Commissioner
Docket Nos. 24029-82, 24064-82
United States Tax Court
90 T.C. 1090; 1988 U.S. Tax Ct. LEXIS 73; 90 T.C. No. 73;
May 25, 1988; As amended May 27, 1988 May 25, 1988, Filed
Decisions will be entered under Rule 155.
D and E are the transferees and former majority shareholders of S,…
Also in this document: Dissent · Nims; Dissent · Hamblen; Dissent · Ruwe.
2Cases cited29 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Endicott Johnson Corp. v. PerkinsSupreme Court of the United States · 1943
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
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