Aragona Trust v. Comm'r
United States Tax Court
T is a trust that owned rental real-estate properties and engaged in other real-estate activities. T's rental real-estate activities would be considered per se passive activities under I.R.C. sec. 469(c)(2) unless T qualified for the exception found in I.R.C. sec. 469(c)(7). This exception is applicable if more than one-half of the personal services performed in trades or businesses by the taxpayer are performed in real-property trades or businesses in which the taxpayer…
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T is a trust that owned rental real-estate properties and engaged in other real-estate activities. T's rental real-estate activities would be considered per se passive activities under I.R.C. sec. 469(c)(2) unless T qualified for the exception found in I.R.C. sec. 469(c)(7). This exception is applicable if more than one-half of the personal services performed in trades or businesses by the taxpayer are performed in real-property trades or businesses in which the taxpayer materially participates and if the taxpayer performs more than 750 hours of services during the year in real-property…
1Opinion of the Court
FRANK ARAGONA TRUST, PAUL ARAGONA, EXECUTIVE TRUSTEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Aragona Trust v. Comm'r
Docket No. 15392-11
United States Tax Court
142 T.C. 165; 2014 U.S. Tax Ct. LEXIS 10; 142 T.C. No. 9;
March 27, 2014, Filed
Decision will be entered under Tax Ct. R. Pract. & Proc. 155.
T is a trust that owned rental real-estate properties and engaged in other real-estate activities. T's rental real-estate activities would be considered per se passive activities under I.R.C. sec. 469(c)(2) unless T qualified for the exception found in I.R.C. sec. 469(c)(7). This…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Estate of Bongard v. Comm'rUnited States Tax Court · 2005
- In Re Butterfield EstateMichigan Supreme Court · 1983
- Bronstein v. CommissionerUnited States Tax Court · 2012
- Aragona Trust v. Comm'rUnited States Tax Court · 2014
1 more not listed; retrieve them via the Exa API.