Estate of Wallace v. Commissioner
United States Tax Court
Held, Dr. Gerald L. Wallace (petitioner) was a limited entrepreneur who did not actively participate in his cattle feeding business and therefore was entitled under sec. 464 to deduct only the cost of feed purchased which was actually consumed by the cattle during the year.
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Held, Dr. Gerald L. Wallace (petitioner) was a limited entrepreneur who did not actively participate in his cattle feeding business and therefore was entitled under sec. 464 to deduct only the cost of feed purchased which was actually consumed by the cattle during the year. Held, further: The income received by petitioner from a subchapter S corporation in which he owned a 70-percent interest consisted of personal service income, within the meaning of sec. 1348, and dividends. The amount of petitioner's earned income from personal services rendered to the subchapter S corporation is…
1Opinion of the Court
SCOTT, Judge:
Respondent determined deficiencies in petitioners’ income tax for the calendar years 1980 and 1983 in the amounts of $303,129 and $566,236, respectively. Dr. Gerald L. Wallace (Dr. Wallace) died on November 13, 1986, prior to the issuance of the notice of deficiency in this case. However, since the years here involved are 1980 and 1983, we will hereinafter refer to Dr. and Mrs. Wallace as petitioners. Some of the issues raised by the pleadings have been disposed of by agreement of the parties, leaving for our decision the following:(1) Whether the amount of deductions to which…
2Cases cited28 opinions
- Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Federal Power Commission v. Memphis Light, Gas & Water DivisionSupreme Court of the United States · 1973
- Chester D. Tripp, Chester D. Tripp, Surviving Spouse Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- J. C. Penney Company, Transferee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
23 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Allen v. Comm'rUnited States Tax Court · 2002
- Estate of Gerald L. Wallace, Deceased, Celia A. Wallace, and Celia A. Wallace v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1992
- Redlark v. Comm'rUnited States Tax Court · 1996
- Robinson v. Comm'rUnited States Tax Court · 2002
- Estate of Clayton v. CommissionerUnited States Tax Court · 1991
50 more not listed; retrieve them via the Exa API.