Warbus v. Commissioner
United States Tax Court
P, a member of a federally recognized tribe of American Indians, purchased a boat that he used in treaty "fishing- rights-related" activity as defined in sec. 7873, I.R.C. In 1984, P obtained a commercial loan for items related to the fishing boat from the same lender who financed the purchase of the boat.
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P, a member of a federally recognized tribe of American Indians, purchased a boat that he used in treaty "fishing- rights-related" activity as defined in sec. 7873, I.R.C. In 1984, P obtained a commercial loan for items related to the fishing boat from the same lender who financed the purchase of the boat. The loan repayment was guaranteed by the Bureau of Indian Affairs (BIA). When P failed to make payments on the loan as they became due, the lender repossessed and sold the boat. In 1993, pursuant to its loan guaranty, the BIA paid to the lender outstanding principal and interest, which it…
1Opinion of the Court
OPINION
Parr, Judge:
This case was heard by Special Trial Judge John F. Dean pursuant to section 7443A(b) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Dean, Special Trial Judge:
Respondent determined a deficiency in petitioner’s 1993 Federal income tax of $3,054 and additions to tax of $763.50 under section 6651(a) and $127.92 under section 6654(a). Petitioner concedes that he received unreported rental income of $6,000 and nonemployee compensation of $3,700 subject to…
2Cases cited12 opinions
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Commissioner v. TuftsSupreme Court of the United States · 1983
- Bowers v. Kerbaugh-Empire Co.Supreme Court of the United States · 1926
- HCSC-Laundry v. United StatesSupreme Court of the United States · 1981
- United States v. Centennial Savings Bank FSBSupreme Court of the United States · 1991
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3Cited by6 opinions
- Jacques L. French & Sherry L. French v. CommissionerUnited States Tax Court · 2018
- Liotti v. Comm'rUnited States Tax Court · 2011
- Martins v. Comm'rUnited States Tax Court · 2006
- Richard Leo Warbus v. CommissionerUnited States Tax Court · 1998
- Sassani v. Comm'rUnited States Tax Court · 2012
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