Nicholson v. Commissioner
United States Tax Court
P, a dentist, purchased two dental clinics in September 1979 and May 1980, respectively. P initially leased those clinics (including all dental equipment) to Gerber, who managed them as described below. In August 1980, P substituted DMA, his wholly owned corporation, for Gerber as lessee and manager on the same terms.
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P, a dentist, purchased two dental clinics in September 1979 and May 1980, respectively. P initially leased those clinics (including all dental equipment) to Gerber, who managed them as described below. In August 1980, P substituted DMA, his wholly owned corporation, for Gerber as lessee and manager on the same terms. CSN, another corporation wholly owned by P, was a "dental practice owner". CSN ran a dental practice by, in effect, subletting space in the dental clinics from Gerber and DMA and hiring dentists to service the patients. P, as an individual, worked as an "associate dentist" for…
1Opinion of the Court
CHARLES S. NICHOLSON AND LINDA S. NICHOLSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Nicholson v. Commissioner
Docket Nos. 23884-88, 24549-88
United States Tax Court
T.C. Memo 1993-183; 1993 Tax Ct. Memo LEXIS 182; 65 T.C.M. (CCH) 2478;
April 26, 1993, Filed
Decisions will be entered under Rule 155.
P, a dentist, purchased two dental clinics in September 1979 and May 1980, respectively. P initially leased those clinics (including all dental equipment) to Gerber, who managed them as described below. In August 1980, P substituted DMA, his wholly owned corporation, for Gerber as…
2Cases cited26 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Dreicer v. CommissionerUnited States Tax Court · 1982
- Petzoldt v. CommissionerUnited States Tax Court · 1989
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
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- Kim v. CommissionerUnited States Tax Court · 2000
- Kuhl v. CommissionerUnited States Tax Court · 1993
- Nguyen v. CommissionerUnited States Tax Court · 1993
- Nicholson v. CommissionerUnited States Tax Court · 1993
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