Legal Opinion

Hillman v. Comm'r

United States Tax Court

Decided April 9, 2002No. 19893-97Published

P's S corporation (S) performed management services for real estate partnerships in which P had direct and indirect interests. P actively participated in S by performing management services that S had contracted to perform for the partnerships. P was not an active participant in any of the partnerships.

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P's S corporation (S) performed management services for real estate partnerships in which P had direct and indirect interests. P actively participated in S by performing management services that S had contracted to perform for the partnerships. P was not an active participant in any of the partnerships. On the Schedule K-1 issued to P from S, P's portion of the management income was reduced by the portion of the corresponding management fee expense paid by the partnerships to S in an amount proportionate to P's ownership percentage in each partnership. The reduction from the management income…

1Opinion of the Court

DAVID H. AND SUZANNE HILLMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent *

Hillman v. Comm'r

No. 19893-97

United States Tax Court

118 T.C. 323; 2002 U.S. Tax Ct. LEXIS 18; 118 T.C. No. 17;

April 9, 2002, Filed

Respondent's determination that petitioners were not entitled to reduce management income by the management fee deduction of real estate entities was not in error.

P's S corporation (S) performed management services for real

estate partnerships in which P had direct and indirect

interests. P actively participated in S by performing management

services that S had contracted to…

2Cases cited6 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  3. David H. Hillman Suzanne Hillman v. Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 2001
  4. Hillman v. CommissionerUnited States Tax Court · 2000
  5. David H. Hillman Suzanne Hillman v. Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 2001

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