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.
Read the full summary
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
OPINION
Laro, Judge:
This case was submitted to the Court without trial. See Rule 122.2 Petitioners petitioned the Court to redetermine respondent’s determination of the following deficiencies in their Federal income taxes for 1994 and 1995:
Petitioner 1994 1995
Charles C. Allen III and Barbara N. Allen $21,321 $12,107
Charles C. Allen, Jr. 21,324 12,015
John R. Allen and Estate of Sally F. Allen 21,395
John R. and Judith M. Allen 12,108
John R. Allen, Jr., and Susan S. Allen 21,394 12,107
Warren L. Allen 6,388 1,970
Warren L. Allen, Jr. 36,197 20,582
Amantha S. Allen 36,197 20,582
Following concessions…
2Cases cited24 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
19 more not listed; retrieve them via the Exa API.
3Cited by81 opinions
- Montgomery v. Comm'rUnited States Tax Court · 2004
- Ewing v. CommissionerUnited States Tax Court · 2002
- Montgomery v. Comm'rUnited States Tax Court · 2006
- Merlo v. Comm'rUnited States Tax Court · 2006
- King v. Comm'rUnited States Tax Court · 2003
76 more not listed; retrieve them via the Exa API.