Conole v. Commissioner
United States Tax Court
Held: (1) The lease of property by petitioner to a corporation, 50 percent of the stock of which was owned by petitioner, was a valid lease. Held: (2) Property leased by petitioner to a corporation, 50 percent of the stock of which was owned by petitioner, was utilized for both business and the personal activities of petitioner.
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Held: (1) The lease of property by petitioner to a corporation, 50 percent of the stock of which was owned by petitioner, was a valid lease. Held: (2) Property leased by petitioner to a corporation, 50 percent of the stock of which was owned by petitioner, was utilized for both business and the personal activities of petitioner. Allocation established: (a) With respect to each of the years in question, petitioner is chargeable with income to the extent of an allocable portion of the total cost incurred by the corporation in the operation of the property. 468 (b) With respect to 1961,…
1Opinion of the Court
Clement V. and Marjorie A. Conole v. Commissioner.
Conole v. Commissioner
Docket No. 4916-67.
United States Tax Court
T.C. Memo 1971-111; 1971 Tax Ct. Memo LEXIS 219; 30 T.C.M. (CCH) 467; T.C.M. (RIA) 71111;
May 18, 1971, Filed.
Held: (1) The lease of property by petitioner to a corporation, 50 percent of the stock of which was owned by petitioner, was a valid lease.
Held: (2) Property leased by petitioner to a corporation, 50 percent of the stock of which was owned by petitioner, was utilized for both business and the personal activities of petitioner. Allocation established:(a) With respect to…
2Cases cited14 opinions
- Heuer v. CommissionerUnited States Tax Court · 1959
- Louis Greenspon v. Commissioner of Internal Revenue, (Three Cases). Anna Greenspon v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956
- International Artists, Ltd. v. CommissionerUnited States Tax Court · 1970
- M. E. Blatt Co. v. United StatesSupreme Court of the United States · 1938
- C. Louis Wood and Hallie D. Wood v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
9 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Clement v. And Marjorie A. Conole, Petitioners-Appellants-Cross v. Commissioner of Internal Revenue, Respondent-Appellee-CrossCourt of Appeals for the Fifth Circuit · 1973
- Clement v. And Marjorie A. Conole, Petitioners-Appellants-Cross v. Commissioner of Internal Revenue, Respondent-Appellee-CrossCourt of Appeals for the Fifth Circuit · 1973