Historic House Museum Corp. v. Commissioner
United States Tax Court
Petitioner, a private foundation under sec. 509(a), I.R.C. 1954, maintained a house with historic attributes. Its sole income was from interest and it had no expenses connected with such income. Held, maintenance expenses and taxes in respect of such house are not deductible in computing petitioner's "net investment income" upon which the 4-percent excise tax under sec. 4940(a), I.R.C. 1954, is imposed.
1Opinion of the Court
Historic House Museum Corp., Petitioner v. Commissioner of Internal Revenue, Respondent
Historic House Museum Corp. v. Commissioner
Docket No. 3179-76
United States Tax Court
70 T.C. 12; 1978 U.S. Tax Ct. LEXIS 142;
April 5, 1978, Filed
Decision will be entered for the respondent.
Petitioner, a private foundation under sec. 509(a), I.R.C. 1954, maintained a house with historic attributes. Its sole income was from interest and it had no expenses connected with such income. Held, maintenance expenses and taxes in respect of such house are not deductible in computing petitioner's "net investment…
2Cases cited6 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Adirondack League Club v. CommissionerUnited States Tax Court · 1971
- Historic House Museum Corp. v. CommissionerUnited States Tax Court · 1978
- Julia R. & Estelle L. Foundation, Inc. v. CommissionerUnited States Tax Court · 1978
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