Legal Opinion

Patel v. Commissioner

United States Tax Court

Decided February 1, 1988No. Docket No. 4542-85UnpublishedCited by 5 opinions

(1) P and his wife owned several motels during the years in issue. They operated some motels themselves and leased others to T, a corporation owned by them.

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(1) P and his wife owned several motels during the years in issue. They operated some motels themselves and leased others to T, a corporation owned by them. Ps and their family resided in an apartment in one of such motels and continued to do so after such motel was leased to T. Held, Ps received constructive dividends from T equal to the fair rental value of the apartment furnished to them by T. Held, further, the Commissioner's determinations with respect to numerous items of income redetermined. Held, further, Ps are not entitled to investment tax credits on property leased by them for use…

1Opinion of the Court

CHANDRAKANT B. PATEL and S. C. PATEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Patel v. Commissioner

Docket No. 4542-85.

United States Tax Court

T.C. Memo 1988-33; 1988 Tax Ct. Memo LEXIS 33; 55 T.C.M. (CCH) 2; T.C.M. (RIA) 88033;

February 1, 1988.(1) P and his wife owned several motels during the years in issue. They operated some motels themselves and leased others to T, a corporation owned by them. Ps and their family resided in an apartment in one of such motels and continued to do so after such motel was leased to T. Held, Ps received constructive dividends from T equal to…

2Cases cited20 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Giddio v. CommissionerUnited States Tax Court · 1970
  3. Courtney v. CommissionerUnited States Tax Court · 1957
  4. International Artists, Ltd. v. CommissionerUnited States Tax Court · 1970
  5. Albert Schoenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962

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

3Cited by5 opinions

  1. Estate of Foster v. CommissionerUnited States Tax Court · 1988
  2. Grace Foreign Exch. Corp. v. CommissionerUnited States Tax Court · 1994
  3. Langlois v. CommissionerUnited States Tax Court · 1988
  4. Miller v. CommissionerUnited States Tax Court · 1993
  5. Sparrow v. CommissionerUnited States Tax Court · 1988

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