Estate of Wallace v. Commissioner
United States Tax Court
Held, Dr. Gerald L. Wallace (petitioner) was a limited entrepreneur who did not actively participate in his cattle feeding business and therefore was entitled under sec. 464 to deduct only the cost of feed purchased which was actually consumed by the cattle during the year.
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Held, Dr. Gerald L. Wallace (petitioner) was a limited entrepreneur who did not actively participate in his cattle feeding business and therefore was entitled under sec. 464 to deduct only the cost of feed purchased which was actually consumed by the cattle during the year. Held, further: The income received by petitioner from a subchapter S corporation in which he owned a 70-percent interest consisted of personal service income, within the meaning of sec. 1348, and dividends. The amount of petitioner's earned income from personal services rendered to the subchapter S corporation is…
1Opinion of the Court
Estate of Gerald L. Wallace, Deceased, Celia A. Wallace, Executrix, and Celia A. Wallace, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Wallace v. Commissioner
Docket No. 22960-88
United States Tax Court
95 T.C. 525; 1990 U.S. Tax Ct. LEXIS 106; 95 T.C. No. 37;
November 14, 1990, Filed
Decision will be entered under Rule 155.
Held, Dr. Gerald L. Wallace (petitioner) was a limited entrepreneur who did not actively participate in his cattle feeding business and therefore was entitled under sec. 464 to deduct only the cost of feed purchased which was actually consumed by the…
2Cases cited29 opinions
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Federal Power Commission v. Memphis Light, Gas & Water DivisionSupreme Court of the United States · 1973
- Chester D. Tripp, Chester D. Tripp, Surviving Spouse Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
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