Legal Opinion

Beals v. Commissioner

United States Tax Court

Decided March 30, 1987No. Docket No. 16748-82UnpublishedCited by 4 opinions

P devoted his full time to the management of the extensive investments owned by him and his family. He treated the dividends received by him as earned income subject to the maximum tax provided by sec. 1348, I.R.C. 1954. Held, the management of investments is not a trade or business for such purposes.

1Opinion of the Court

E. MAURAN BEALS and JULIA O. BEALS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Beals v. Commissioner

Docket No. 16748-82.

United States Tax Court

T.C. Memo 1987-171; 1987 Tax Ct. Memo LEXIS 167; 53 T.C.M. (CCH) 492; T.C.M. (RIA) 87171;

March 30, 1987.

P devoted his full time to the management of the extensive investments owned by him and his family. He treated the dividends received by him as earned income subject to the maximum tax provided by sec. 1348, I.R.C. 1954. Held, the management of investments is not a trade or business for such purposes.

Edward DeFranceschi and Joan…

2Cases cited7 opinions

  1. Higgins v. CommissionerSupreme Court of the United States · 1941
  2. Whipple v. CommissionerSupreme Court of the United States · 1963
  3. Snyder v. CommissionerSupreme Court of the United States · 1935
  4. Ralph E. Purvis and Patricia Lee Purvis, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
  5. Ditunno v. CommissionerUnited States Tax Court · 1983

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

3Cited by4 opinions

  1. Cameron v. Comm'rUnited States Tax Court · 2007
  2. Ames D. Ray v. CommissionerUnited States Tax Court · 2019
  3. Lender Management, LLC, Marvin K. Lender Revocable Trust, Tax Matters Partner v. CommissionerUnited States Tax Court · 2017
  4. Mayer v. CommissionerUnited States Tax Court · 1994

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