Sangers Home for Chronic Patients v. Comm'r
United States Tax Court
Held, petitioners are precluded by applying the doctrine of equitable estoppel from asserting that the taxable income or losses of Sangers Home for Chronic Patients, Inc., from the operation of a nursing home business for the years 1966 through 1971 should have been reported by an individual proprietorship from 1966 to May 4, 1967, and by a partnership from May 4, 1967 through 1971.
1Opinion of the Court
Dawson, Judge:
In these consolidated cases respondent determined the following deficiencies in the Federal income taxes of petitioners:
Petitioners Year Deficiency
Sangers Home for Chronic Patients, Inc. 1970 $10,675.91
Charles Ekblom and Elizabeth Sanger Ekblom . 1966 9,987.34
1967 32,544.34
1968 32,255.08
1969 43,494.06
1970 31,190.71
1971 19,991.09
Upon agreement of the parties the Court severed the issue of whether Sangers Home for Chronic Patients, Inc., actually conducted the nursing home business and reported the income therefrom on its Federal corporate income tax returns for the years in…
2Cases cited8 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Weigman v. CommissionerUnited States Tax Court · 1967
- Maletis v. United StatesCourt of Appeals for the Ninth Circuit · 1952
- Haag v. CommissionerUnited States Board of Tax Appeals · 1930
- J. Sterling Halstead and Marcella S. Halstead v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
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3Cited by16 opinions
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- Steiner v. CommissionerUnited States Tax Court · 1995
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