International Artists, Ltd. v. Commissioner
United States Tax Court
Held, an allocable portion of depreciation and maintenance expenses with respect to property owned by the corporate petitioner is deductible by the corporation. Such property was acquired and used for both personal and business purposes. Allocation determined.
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Held, an allocable portion of depreciation and maintenance expenses with respect to property owned by the corporate petitioner is deductible by the corporation. Such property was acquired and used for both personal and business purposes. Allocation determined. Held, further, the individual petitioner, president and dominant shareholder of the corporation, is chargeable with income as a result of his personal use of corporate property to the extent of an allocable portion of the fair rental value of the corporate property.
1Opinion of the Court
International Artists, Ltd., Petitioners v. Commissioner of Internal Revenue, Respondent; Walter V. Liberace, Petitioner v. Commissioner of Internal Revenue, Respondent
International Artists, Ltd. v. Commissioner
Docket Nos. 1569-68, 1570-68
United States Tax Court
55 T.C. 94; 1970 U.S. Tax Ct. LEXIS 46;
October 22, 1970, Filed
Decisions will be entered under Rule 50.
Held, an allocable portion of depreciation and maintenance expenses with respect to property owned by the corporate petitioner is deductible by the corporation. Such property was acquired and used for both personal and business…
2Cases cited15 opinions
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Heuer v. CommissionerUnited States Tax Court · 1959
- Louis Greenspon v. Commissioner of Internal Revenue, (Three Cases). Anna Greenspon v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- International Artists, Ltd. v. CommissionerUnited States Tax Court · 1970
- International Trading Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1960
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