Holland v. Commissioner
United States Tax Court
Held: Petitioner realized, and must recognize, $135,000 of additional income in 1974 as a result of his purchase of master recordings via an offset against royalties owed him; petitioner's master recordings activity was not engaged in for profit and, therefore, he is not entitled to the claimed depreciation deduction or investment credit; respondent's disallowance of petitioner's claimed deductions for automobile, travel and hotel expenses, partnership losses, alimony,…
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Held: Petitioner realized, and must recognize, $135,000 of additional income in 1974 as a result of his purchase of master recordings via an offset against royalties owed him; petitioner's master recordings activity was not engaged in for profit and, therefore, he is not entitled to the claimed depreciation deduction or investment credit; respondent's disallowance of petitioner's claimed deductions for automobile, travel and hotel expenses, partnership losses, alimony, charitable contributions, and tax return preparation fees are sustained.
1Opinion of the Court
BRIAN HOLLAND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Holland v. Commissioner
Docket No. 14787-81
United States Tax Court
T.C. Memo 1985-626; 1985 Tax Ct. Memo LEXIS 7; 51 T.C.M. (CCH) 164; T.C.M. (RIA) 85626;
December 26, 1985.
Held: Petitioner realized, and must recognize, $135,000 of additional income in 1974 as a result of his purchase of master recordings via an offset against royalties owed him; petitioner's master recordings activity was not engaged in for profit and, therefore, he is not entitled to the claimed depreciation deduction or investment credit; respondent's…
2Cases cited23 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Golanty v. CommissionerUnited States Tax Court · 1979
18 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Holland v. CommissionerCourt of Appeals for the Ninth Circuit · 1987
- Brian Holland v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987