Legal Opinion

Notter v. Commissioner

United States Tax Court

Decided August 5, 1985No. Docket No. 129-82UnpublishedCited by 1 opinion

Held: (1) Petitioners are not entitled to a casualty loss deduction under section 165(c)(3), I.R.C. 1954, for 1978. (2) Petitioners are not entitled to a residential energy credit under section 44C, I.R.C. 1954, for 1978 and 1979. (3) Petitioners are not entitled to deduct patent licensing expenses for 1978 and 1979. (4) Liability determined for additions to tax under section 6653(a), I.R.C. 1954, for 1978 and 1979.

1Opinion of the Court

GEORGE K. NOTTER AND LORRAINE B. NOTTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Notter v. Commissioner

Docket No. 129-82.

United States Tax Court

T.C. Memo 1985-391; 1985 Tax Ct. Memo LEXIS 244; 50 T.C.M. (CCH) 614; T.C.M. (RIA) 85391;

August 5, 1985.

Held: (1) Petitioners are not entitled to a casualty loss deduction under section 165(c)(3), I.R.C. 1954, for 1978.(2) Petitioners are not entitled to a residential energy credit under section 44C, I.R.C. 1954, for 1978 and 1979.(3) Petitioners are not entitled to deduct patent licensing expenses for 1978 and 1979.(4) Liability…

2Cases cited11 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Bixby v. CommissionerUnited States Tax Court · 1972
  3. Helvering v. OwensSupreme Court of the United States · 1939
  4. Reiff v. CommissionerUnited States Tax Court · 1981
  5. Lamphere v. CommissionerUnited States Tax Court · 1978

6 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Weyerhaeuser Co. v. United StatesUnited States Court of Federal Claims · 1994

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