Allen v. Comm'r
United States Tax Court
Ps are the shareholders of F, a subch. S corporation. During its 1994 and 1995 taxable years, F incurred wages that qualified for the targeted jobs credit (TJC) under secs. 38 and 51, I.R.C. F claimed TJCs of $ 456,264 and $ 259,434 for the respective years and reported to Ps their proportionate shares of the credits.
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Ps are the shareholders of F, a subch. S corporation. During its 1994 and 1995 taxable years, F incurred wages that qualified for the targeted jobs credit (TJC) under secs. 38 and 51, I.R.C. F claimed TJCs of $ 456,264 and $ 259,434 for the respective years and reported to Ps their proportionate shares of the credits. F reduced its deduction of wages by the amount of the TJCs, pursuant to sec. 280C(a), I.R.C., and reported to Ps their proportionate shares of its resulting net income (F's resulting net income). Ps computed their regular tax liability by including F's resulting net income in…
1Opinion of the Court
CHARLES C. ALLEN, III AND BARBARA N. ALLEN, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Allen v. Comm'r
No. 1287-00; No. 1288-00; No. 1289-00; No. 1290-00; No. 1291-00; No. 1292-00; No. 1293-00; No. 1618-00
United States Tax Court
118 T.C. 1; 2002 U.S. Tax Ct. LEXIS 1; 118 T.C. No. 1;
January 4, 2002, Filed
Decisions will be entered for respondent in docket Nos. 1287-00, 1288-00, 1289-00, 1290-00, 1293-00, and 1618-00, and decisions will be entered under Rule 155 in docket Nos. 1291-00 and 1292-00.
Ps are the shareholders of F, a subch. S corporation.
During its 1994 and 1995…
2Cases cited25 opinions
- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Garcia v. United StatesSupreme Court of the United States · 1985
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