Hayden v. Commissioner
United States Tax Court
Ps are the sole partners in L. During 1994, L expended $ 26,650 on sec. 179 property and elected to expense $ 17,500 of that amount. Without regard to this deduction, L had no taxable income for the 1994 taxable income. The deduction under sec. 179 flowed through to Ps' 1994 return.
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Ps are the sole partners in L. During 1994, L expended $ 26,650 on sec. 179 property and elected to expense $ 17,500 of that amount. Without regard to this deduction, L had no taxable income for the 1994 taxable income. The deduction under sec. 179 flowed through to Ps' 1994 return. Sec. 1.179-2(c)(2), Income Tax Regs., provides that a "partnership may not allocate to its partners as a sec. 179 expense deduction for any taxable year more than the partnership's taxable income limitation for that taxable year". Ps contend that the regulation is invalid. HELD: Sec. 1.179-2(c)(2), Income Tax…
1Opinion of the Court
DENNIS L. HAYDEN AND SHARON E. HAYDEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hayden v. Commissioner
No. 590-98
United States Tax Court
112 T.C. 115; 1999 U.S. Tax Ct. LEXIS 11; 112 T.C. No. 11;
March 19, 1999, Filed
Decision will be entered for respondent.
Ps are the sole partners in L. During 1994, L expended
$ 26,650 on sec. 179 property and elected to expense $ 17,500
of that amount. Without regard to this deduction, L had no
taxable income for the 1994 taxable income. The deduction
under sec. 179 flowed through to Ps' 1994 return. Sec.
1.179-2(c)(2), Income Tax Regs., provides…
2Cases cited20 opinions
- Freytag v. CommissionerSupreme Court of the United States · 1991
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
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