Taproot Admin. Servs. v. Comm'r
United States Tax Court
R determined that P is ineligible for S corporation status in 2003 because its shareholder was a Roth individual retirement account (Roth IRA). As a consequence, R determined that P is taxable as a C corporation for 2003. Held: The Roth IRA is not an eligible S corporation shareholder. P is taxable as a C corporation for 2003.
1Opinion of the Court
TAPROOT ADMINISTRATIVE SERVICES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Taproot Admin. Servs. v. Comm'r
No. 15396-07
United States Tax Court
133 T.C. 202; 2009 U.S. Tax Ct. LEXIS 29; 133 T.C. No. 9;
September 29, 2009, Filed
R determined that P is ineligible for S corporation status in 2003 because its shareholder was a Roth individual retirement account (Roth IRA). As a consequence, R determined that P is taxable as a C corporation for 2003.
Held: The Roth IRA is not an eligible S corporation shareholder. P is taxable as a C corporation for 2003.
Steven R. Mather and…
Also in this document: Concurrence; Dissent.
2Cases cited66 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Patterson v. McLean Credit UnionSupreme Court of the United States · 1989
- Central Bank of Denver, N. A. v. First Interstate Bank of Denver, N. A.Supreme Court of the United States · 1994
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