Lofstrom v. Comm'r
United States Tax Court
Ps are Mr. Lofstrom (H) and Paula Lofstrom (W-2). H was previously married to Dorothy Lofstrom (W-1). In satisfaction of his alimony obligations to W-1, H transferred his $ 29,000 interest in a contract for deed to W-1, along with $ 4,000 in cash. Ps deducted as alimony the value of the contract for deed. In addition, Ps claimed to operate the first floor of their residence as a bed and breakfast (B&B) and deducted related expenses.
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Ps are Mr. Lofstrom (H) and Paula Lofstrom (W-2). H was previously married to Dorothy Lofstrom (W-1). In satisfaction of his alimony obligations to W-1, H transferred his $ 29,000 interest in a contract for deed to W-1, along with $ 4,000 in cash. Ps deducted as alimony the value of the contract for deed. In addition, Ps claimed to operate the first floor of their residence as a bed and breakfast (B&B) and deducted related expenses. H, a retired doctor, also claimed to be engaged in the business of writing for profit and Ps deducted expenses attributable to H's writing activities. 1. Held: A…
1Opinion of the Court
OPINION
Kroupa, Judge:
Respondent determined a $10,552 deficiency in petitioners’ Federal income tax for 1997 and a $2,198 deficiency for 1998. After concessions,1 the issues for decision are:(1) Whether petitioners may claim an alimony deduction for $29,000 in 1997 for the transfer of a contract for deed. Because we find the contract for deed does not constitute cash or a cash equivalent, we hold that they may not;(2) whether petitioners may deduct $19,158 in 1997 for expenses incurred in the operation of a bed and breakfast (B&B). Because we find they used the B&B for personal purposes for an…
2Cases cited29 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Dreicer v. CommissionerUnited States Tax Court · 1982
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3Cited by17 opinions
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- Estate of Cicero Ioan Limberea, Liudmila Caraman, and Liudmila Caraman v. CommissionerUnited States Tax Court · 2013
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