Swallows Holding, Ltd. v. Comm'r
United States Tax Court
P is a foreign corporation whose only substantial asset is unimproved land in the United States. On its 1994, 1995, and 1996 Federal income tax returns, P recognized rent and option income and claimed deductions for taxes and licenses, the result of which was a reported loss for each year.
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P is a foreign corporation whose only substantial asset is unimproved land in the United States. On its 1994, 1995, and 1996 Federal income tax returns, P recognized rent and option income and claimed deductions for taxes and licenses, the result of which was a reported loss for each year. P filed each return after its due date, but before any contact from R. R determined that sec. 882(c)(2), I.R.C., precluded P from deducting its expenses because it filed its returns untimely. In Anglo-Am. Direct Tea Trading Co. v. Commissioner, 38 B.T.A. 711 (1938), a setting similar to that here, the Board…
1Opinion of the Court
SWALLOWS HOLDING, LTD., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Swallows Holding, Ltd. v. Comm'r
No. 8045-02
United States Tax Court
126 T.C. 96; 2006 U.S. Tax Ct. LEXIS 6; 126 T.C. No. 6;
January 26, 2006, Filed
P is a foreign corporation whose only substantial asset is
unimproved land in the United States. On its 1994, 1995, and
1996 Federal income tax returns, P recognized rent and option
income and claimed deductions for taxes and licenses, the result
of which was a reported loss for each year. P filed each return
after its due date, but before any contact from R. R determined
that…
Also in this document: Dissent · Swift; Dissent · Halpern; Dissent · Holmes.
2Cases cited138 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co.Supreme Court of the United States · 1983
- Welch v. HelveringSupreme Court of the United States · 1933
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- Marbury v. MadisonSupreme Court of the United States · 1803
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