Hirasuna v. Commissioner
United States Tax Court
Petitioner-husbands were professional dentists. Ps purchased or leased farm property in the San Joaquin Valley, California, from Pacific Agricultural Services, Inc. (Pac Ag). Ps and Pac Ag entered into contracts whereby Pac Ag agreed to plant and manage the farm property.
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Petitioner-husbands were professional dentists. Ps purchased or leased farm property in the San Joaquin Valley, California, from Pacific Agricultural Services, Inc. (Pac Ag). Ps and Pac Ag entered into contracts whereby Pac Ag agreed to plant and manage the farm property. Ps filed a motion for summary judgment seeking an adjudication that they are not members of a farming syndicate as defined in sec. 464(c)(1)(B), I.R.C. 1954. R filed a cross-motion for partial summary judgment alleging that Ps were members of an "enterprise" from which more than 35 percent of the losses were allocable to…
1Opinion of the Court
OPINION
PARR, Judge:
These consolidated cases Eire before the Court on petitioners’ motion for summary judgment filed on December 18, 1986, and respondent’s cross-motion for partial summary judgment filed on March 9, 1987. Both petitioners’ motion and respondent’s cross-motion included a memorEmdum of law, affidavits, Emd exhibits. Petitioners filed a memorandum in reply to respondent’s cross-motion on May 12, 1987.
In a notice of deficiency dated July 11, 1983, respondent determined deficiencies in John and Claudia Hirasuna’s Federal income tax for 1980 and 1981 as follows:
Taxable year Amount
198…
2Cases cited8 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Jacklin v. CommissionerUnited States Tax Court · 1982
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Gulfstream Land & Development Corp. v. CommissionerUnited States Tax Court · 1979
3 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Woods v. CommissionerUnited States Tax Court · 1988
- Allen v. Comm'rUnited States Tax Court · 2002
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
- UNITED STATES TAX COURT FRONTIER CHEVROLET CO. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Nordtvedt v. CommissionerUnited States Tax Court · 2001
10 more not listed; retrieve them via the Exa API.