McKinney v. Commissioner
United States Tax Court
Held, petitioners' rental of their Hawaiian condominium is an activity engaged in for profit; Held further, a previous judgment against petitioners in a refund action for different taxable years does not estop petitioners from litigating the issues in the instant case; Held further, allowable deductions determined under section 212 and also under section 280A for 1976.
1Opinion of the Court
EDITH G. McKINNEY and ESTATE OF JAMES R. McKINNEY, DECEASED, EDITH G. McKINNEY, EXECUTRIX, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
McKinney v. Commissioner
Docket No. 5437-78.
United States Tax Court
T.C. Memo 1981-181; 1981 Tax Ct. Memo LEXIS 563; 41 T.C.M. (CCH) 1272; T.C.M. (RIA) 81181;
April 15, 1981.
Held, petitioners' rental of their Hawaiian condominium is an activity engaged in for profit; Held further, a previous judgment against petitioners in a refund action for different taxable years does not estop petitioners from litigating the issues in the instant case; Held…
2Cases cited10 opinions
- Montana v. United StatesSupreme Court of the United States · 1979
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Engdahl v. CommissionerUnited States Tax Court · 1979
- Churchman v. CommissionerUnited States Tax Court · 1977
5 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Bolton v. CommissionerUnited States Tax Court · 1981
- Dorance D. And Helen A. Bolton v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
- Bolton v. CommissionerUnited States Tax Court · 1981