Rousku v. Commissioner
United States Tax Court
Petitioner, as sole proprietor, operated an automobile body repair business during 1967, when he was a bona fide resident of Canada. For use in his business, he rented and later purchased garage space; owned necessary machinery, including air compressors, welding equipment, grinders, sanders, and paint-spraying equipment; and carried an inventory of fenders, bumpers, and other parts.
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Petitioner, as sole proprietor, operated an automobile body repair business during 1967, when he was a bona fide resident of Canada. For use in his business, he rented and later purchased garage space; owned necessary machinery, including air compressors, welding equipment, grinders, sanders, and paint-spraying equipment; and carried an inventory of fenders, bumpers, and other parts. Held, petitioner was engaged in a business in which capital was a material income-producing factor and is subject to the 30-percent limitation on the exclusion from gross income prescribed by sec. 911(b), I.R.C.…
1Opinion of the Court
Fbatheeston, Judge:
Respondent determined a deficiency in petitioners’ income tax for 1967 in the amount of $784.73. The only issue presented for decision is whether, within the meaning of section 911,1 capital was a material income-producing factor in an automobile body repair business which petitioner George Rousku conducted in Canada.
BINDINGS OB BACT
George Rousku (hereinafter referred to as petitioner) and Esther Rousku, citizens of the United States, were legal residents of Leaming-ton, Ontario, Canada, at the time their petition was filed. They filed their joint Federal income tax return…
2Cases cited9 opinions
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Fairfax Mut. Wood Products Co. v. CommissionerUnited States Tax Court · 1945
- Miller v. CommissionerUnited States Tax Court · 1969
- Edward P. Allison Co. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1933
- William A. Corrao Electric Co. v. CommissionerUnited States Board of Tax Appeals · 1931
4 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Moore v. CommissionerUnited States Tax Court · 1979
- Thomas v. CommissionerUnited States Tax Court · 1989
- Bruno v. CommissionerUnited States Tax Court · 1978
- Gaudern v. CommissionerUnited States Tax Court · 1981
- Graham v. CommissionerUnited States Tax Court · 1982
31 more not listed; retrieve them via the Exa API.