Legal Opinion

Crook v. Commissioner

United States Tax Court

Decided January 10, 1983No. Docket No. 18704-80Published

Petitioners paid substantial amounts of "investment interest" subject to the limitation of sec. 163(d), I.R.C. 1954. Petitioners are also shareholders of three subch. S corporations each of which derives all its income from the operation of an automobile dealership. Petitioners were required to include in their individual gross income both actual distributions and undistributed taxable income of each corporation.

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Petitioners paid substantial amounts of "investment interest" subject to the limitation of sec. 163(d), I.R.C. 1954. Petitioners are also shareholders of three subch. S corporations each of which derives all its income from the operation of an automobile dealership. Petitioners were required to include in their individual gross income both actual distributions and undistributed taxable income of each corporation. Held, sec. 163(d)(4)(C), I.R.C. 1954, does not attribute the character of a subch. S corporation's operating income to its shareholders for purposes of the sec. 163(d) limitation.…

1Opinion of the Court

William H. Crook and Eleanor B. Crook, Petitioners v. Commissioner of Internal Revenue, Respondent

Crook v. Commissioner

Docket No. 18704-80

United States Tax Court

80 T.C. 27; 1983 U.S. Tax Ct. LEXIS 130; 80 T.C. No. 2;

January 10, 1983, Filed

Decision will be entered under Rule 155.

Petitioners paid substantial amounts of "investment interest" subject to the limitation of sec. 163(d), I.R.C. 1954. Petitioners are also shareholders of three subch. S corporations each of which derives all its income from the operation of an automobile dealership. Petitioners were required to include in their…

2Cases cited8 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  3. United States v. One 1936 Model Ford V-8 De Luxe Coach, Commercial Credit Co.Supreme Court of the United States · 1939
  4. Evans v. GoreSupreme Court of the United States · 1920
  5. Howell v. CommissionerUnited States Tax Court · 1972

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