Rose v. Commissioner
United States Tax Court
Ps purchased "Reproduction Masters" of Picasso originals from Jackie Fine Arts, in transactions that can be characterized as "generic tax shelters."
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Ps purchased "Reproduction Masters" of Picasso originals from Jackie Fine Arts, in transactions that can be characterized as "generic tax shelters." Held: 1. Applying an objective analysis, the transactions lacked economic substance apart from anticipated tax benefits, and Ps are not entitled to depreciation or miscellaneous deductions or investment tax credits on the property acquired. 2. Ps are entitled to deduct under sec. 163, I.R.C. 1954, as amended, interest actually paid on recourse debt incurred. Rice's Toyota World, Inc. v. Commissioner, 752 F.2d 89 (4th Cir. 1985), revg. on this…
1Opinion of the Court
James L. Rose and Judy S. Rose, Petitioners v. Commissioner of Internal Revenue, Respondent
Rose v. Commissioner
Docket No. 25635-83
United States Tax Court
88 T.C. 386; 1987 U.S. Tax Ct. LEXIS 18; 88 T.C. No. 18;
February 5, 1987. February 5, 1987, Filed
Decision will be entered under Rule 155.
Ps purchased "Reproduction Masters" of Picasso originals from Jackie Fine Arts, in transactions that can be characterized as "generic tax shelters." Held:
1. Applying an objective analysis, the transactions lacked economic substance apart from anticipated tax benefits, and Ps are not entitled to depreciation…
2Cases cited70 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
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