Holland v. Commissioner
United States Tax Court
Held: Respondent's disallowance of deductions for legal expenses and partnership losses sustained; petitioner is not entitled to claimed dependency exemptions or to use income averaging in computing his tax liability; and petitioner is liable for additions to tax under sections 6651(a) and 6653(a).
1Opinion of the Court
EDWARD J. HOLLAND, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Holland v. Commissioner
Docket No. 24725-82.
United States Tax Court
T.C. Memo 1985-627; 1985 Tax Ct. Memo LEXIS 8; 51 T.C.M. (CCH) 172; T.C.M. (RIA) 85627;
December 26, 1985.
Held: Respondent's disallowance of deductions for legal expenses and partnership losses sustained; petitioner is not entitled to claimed dependency exemptions or to use income averaging in computing his tax liability; and petitioner is liable for additions to tax under sections 6651(a) and 6653(a).
Hallison H. Young, for the petitioner.
Arthur L.…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. BoyleSupreme Court of the United States · 1985
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Bixby v. CommissionerUnited States Tax Court · 1972
- Enoch v. CommissionerUnited States Tax Court · 1972
15 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Edward J. Holland, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988