Hopper v. Commissioner
United States Tax Court
Income and expenses related to the business of renting self-storage units are found to be "rentals [and deductions] from real estate" within the meaning of sec. 1402(a)(1), I.R.C. 1954, and sec. 1.1402(a)-4(a) and (c), Income Tax Regs., and are therefore excludable from the computation of net earnings from self-employment.
Read the full summary
Income and expenses related to the business of renting self-storage units are found to be "rentals [and deductions] from real estate" within the meaning of sec. 1402(a)(1), I.R.C. 1954, and sec. 1.1402(a)-4(a) and (c), Income Tax Regs., and are therefore excludable from the computation of net earnings from self-employment. P cannot offset his share of the net loss from the self-storage business against income from his law practice in determining net earnings from self-employment which are subject to self-employment tax.
1Opinion of the Court
Roger G. Hopper and Helen H. Hopper, Petitioners v. Commissioner of Internal Revenue, Respondent
Hopper v. Commissioner
Docket No. 22123-87
United States Tax Court
94 T.C. 542; 1990 U.S. Tax Ct. LEXIS 19; 94 T.C. No. 31;
March 27, 1990March 27, 1990, Filed
Decision will be entered for the respondent.
Income and expenses related to the business of renting self-storage units are found to be "rentals [and deductions] from real estate" within the meaning of sec. 1402(a)(1), I.R.C. 1954, and sec. 1.1402(a)-4(a) and (c), Income Tax Regs., and are therefore excludable from the computation of net earnings…
2Cases cited4 opinions
- George F. Delno v. Anthony J. Celebrezze, Secretary of Health, Education and WelfareCourt of Appeals for the Ninth Circuit · 1965
- Johnson v. CommissionerUnited States Tax Court · 1973
- Bobo v. CommissionerUnited States Tax Court · 1978
- Hopper v. CommissionerUnited States Tax Court · 1990