Legal Opinion

Rundlett v. Comm'r

United States Tax Court

Decided September 26, 2011No. Docket No. 13561-09UnpublishedCited by 2 opinions

R issued a notice of deficiency determining deficiencies in Ps' Federal income taxes for Ps' 2005 and 2006 tax years. The deficiencies primarily stem from R's determination that Ps could not deduct expenses exceeding income from their timeshare activity. Held: Ps are liable for a portion of the deficiency for each year as decided herein.

1Opinion of the Court

DOUGLAS AND GINA RUNDLETT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Rundlett v. Comm'r

Docket No. 13561-09.

United States Tax Court

T.C. Memo 2011-229; 2011 Tax Ct. Memo LEXIS 224; 102 T.C.M. (CCH) 307;

September 26, 2011, Filed

Decision will be entered under Rule 155.

R issued a notice of deficiency determining deficiencies in Ps' Federal income taxes for Ps' 2005 and 2006 tax years. The deficiencies primarily stem from R's determination that Ps could not deduct expenses exceeding income from their timeshare activity.

Held: Ps are liable for a portion of the deficiency for each…

2Cases cited8 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  4. Commissioner v. HeiningerSupreme Court of the United States · 1943
  5. Golanty v. CommissionerUnited States Tax Court · 1979

3 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Malik H. Franklin v. CommissionerUnited States Tax Court · 2020
  2. Rodriguez v. Comm'rUnited States Tax Court · 2013

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