Ronnen v. Commissioner
United States Tax Court
Ps. A and B, were shareholders in a corporation which distributed computer software designed to assist nursing homes with State reporting requirements by incorporating State reporting regulations onto the software. Petitioners claimed a 10-percent investment tax credit for the software as a qualified investment.
Read the full summary
Ps. A and B, were shareholders in a corporation which distributed computer software designed to assist nursing homes with State reporting requirements by incorporating State reporting regulations onto the software. Petitioners claimed a 10-percent investment tax credit for the software as a qualified investment. Held, Ps' investment in nursing home computer software had economic substance and was an activity engaged in for profit within the meaning of sec. 183, I.R.C. 1954. Held, further, petitioners' computer software is not tangible personal property or other personal property eligible for…
1Opinion of the Court
CLAPP, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Year Amount
Deborah N. Ronnen 1978 $77,895.00
(docket No. 25736-83) 1979 27,185.00
105,080.00
Year Amount
F. Ritter Shumway and 1975 $ 26,160.54
Estate of Hattie L. Shumway 1977 49,168.86
(docket No. 26816-83) 1978 29,041,67
104,371.07
These cases were consolidated for trial, briefing, and opinion on September 19, 1985. Docket No. 25736-83 has one additional issue for determination. After concessions by the parties, the issues for decision are: (1) Whether Health Systems Ltd. (HSL) was organized as part of…
2Cases cited36 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Golanty v. CommissionerUnited States Tax Court · 1979
31 more not listed; retrieve them via the Exa API.
3Cited by83 opinions
- Levy v. CommissionerUnited States Tax Court · 1988
- Hulter v. CommissionerUnited States Tax Court · 1988
- Comshare, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 1994
- Gantner v. CommissionerUnited States Tax Court · 1988
- Alexander v. Comm'rUnited States Tax Court · 1990
78 more not listed; retrieve them via the Exa API.