Knudsen v. Comm'r
United States Tax Court
Ps filed a motion for reconsideration of our Memorandum Opinion in Knudsen v. Commissioner, T.C. Memo. 2007-340 (Knudsen I). In Knudsen I we held that petitioners were not engaged in their animal breeding activity for profit within the meaning of sec. 183, I.R.C. We concluded that we did not need to decide whether Ps met the requirements under sec. 7491(a), I.R.C., to shift the burden of proof to R because the outcome was based on a preponderance of the evidence.
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Ps filed a motion for reconsideration of our Memorandum Opinion in Knudsen v. Commissioner, T.C. Memo. 2007-340 (Knudsen I). In Knudsen I we held that petitioners were not engaged in their animal breeding activity for profit within the meaning of sec. 183, I.R.C. We concluded that we did not need to decide whether Ps met the requirements under sec. 7491(a), I.R.C., to shift the burden of proof to R because the outcome was based on a preponderance of the evidence. In their motion Ps argue that this Court erred in so concluding. Ps also argue for the first time that each factor under sec.…
1Opinion of the Court
DENNIS L. AND MARGARET J. KNUDSEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent *
Knudsen v. Comm'r
No. 18246-04
United States Tax Court
131 T.C. 185; 2008 U.S. Tax Ct. LEXIS 29; 131 T.C. No. 11;
November 12, 2008., Filed
Knudsen v. Commissioner, T.C. Memo 2007-340, 2007 Tax Ct. Memo LEXIS 376 (T.C., 2007)
Ps filed a motion for reconsideration of our Memorandum Opinion in Knudsen v. Commissioner, T.C. Memo. 2007-340 (Knudsen I). In Knudsen I we held that petitioners were not engaged in their animal breeding activity for profit within the meaning of sec. 183, I.R.C. We concluded that…
2Cases cited14 opinions
- Diane S. Blodgett v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2005
- Knudsen v. Comm'rUnited States Tax Court · 2008
- Vaughn v. CommissionerUnited States Tax Court · 1986
- ESTATE OF QUICK v. COMMISSIONERUnited States Tax Court · 1998
- Robert Griffin Julia Griffin v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2003
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