Antonides v. Commissioner
United States Tax Court
In 1981, Ps purchased a yacht which they immediately leased back to the seller, to be used for chartering to others. In 1982, Ps incurred and claimed as deductions losses from this venture from sources such as repairs and maintenance, depreciation, and financing costs.
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In 1981, Ps purchased a yacht which they immediately leased back to the seller, to be used for chartering to others. In 1982, Ps incurred and claimed as deductions losses from this venture from sources such as repairs and maintenance, depreciation, and financing costs. R disallowed the claimed loss deductions on the ground that Ps' chartering venture was not an activity entered into for profit within the meaning of sec. 183, I.R.C. 1954. Upon consideration of the whole record, held, that Ps have failed to establish that their yacht chartering venture was entered into for profit. Held,…
1Opinion of the Court
Gary Antonides, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Antonides v. Commissioner
Docket Nos. 10364-86, 17542-86, 17543-86
United States Tax Court
91 T.C. 686; 1988 U.S. Tax Ct. LEXIS 128; 91 T.C. No. 45;
September 27, 1988. September 27, 1988, Filed
Decisions will be entered under Rule 155.
In 1981, Ps purchased a yacht which they immediately leased back to the seller, to be used for chartering to others. In 1982, Ps incurred and claimed as deductions losses from this venture from sources such as repairs and maintenance, depreciation, and financing costs. R disallowed…
2Cases cited33 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Bixby v. CommissionerUnited States Tax Court · 1972
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Golanty v. CommissionerUnited States Tax Court · 1979
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
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