Legal Opinion

Packard v. Commissioner

United States Tax Court

Decided March 11, 1975No. Docket Nos. 524-73, 525-73, 526-73PublishedCited by 54 opinions

Three dentist-partners formed a corporation in 1962 to own the building in which they practiced and to lease it and dental equipment to the partnership. Prior to Aug. 1, 1968, the partnership provided its own dental assistants, receptionists, janitor, and general manager. On Aug. 1, 1968, all of the employees of the partnership except the three partners were transferred to the corporation.

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Three dentist-partners formed a corporation in 1962 to own the building in which they practiced and to lease it and dental equipment to the partnership. Prior to Aug. 1, 1968, the partnership provided its own dental assistants, receptionists, janitor, and general manager. On Aug. 1, 1968, all of the employees of the partnership except the three partners were transferred to the corporation. Thereafter the corporation entered into contracts with the partnership, and three other dentists as well, to provide them with complete dental facilities and services. On Aug. 21, 1968, the partnership…

1Opinion of the Court

Drennen, Judge:

In these cases, which were consolidated for trial and opinion, respondent determined the following deficiencies in petitioners’ income tax:

Docket No. Petitioner Year Deficiency

524-73 Ronald C. Packard and 1968 Roma Jean Packard 1969 $696 806

525-73 Floyd L. Packard and 1968 Alice E. Packard 1969 618 760

526-73 H. Von Packard 1968 305

Sheila D. Packard 1968 308

H. Von Packard and Sheila D. Packard 1969 626

The' sole issue presented for decision is whether the three husband-petitioners are entitled to deduct, under section 404, I.R.C. 1954, their proportionate share of the…

2Cases cited14 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  3. Bartels v. BirminghamSupreme Court of the United States · 1947
  4. Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
  5. Sandor v. CommissionerUnited States Tax Court · 1974

9 more not listed; retrieve them via the Exa API.

3Cited by54 opinions

  1. Professional & Executive Leasing v. CommissionerUnited States Tax Court · 1987
  2. Burnetta v. CommissionerUnited States Tax Court · 1977
  3. Kiddie v. CommissionerUnited States Tax Court · 1978
  4. Robinson v. Comm'rUnited States Tax Court · 2011
  5. Genshaft v. CommissionerUnited States Tax Court · 1975

49 more not listed; retrieve them via the Exa API.

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