Legal Opinion
Joseph A. & Dorothy D. Moller v. The United States
Court of Appeals for the Federal Circuit
Decided November 18, 1983No. Appeal 83-870PublishedCited by 43 opinions
1Opinion of the Court
KASHIWA, Circuit Judge.
This is an appeal by the United States from a judgment of the Claims Court granting taxpayers, Joseph A. and Dorothy D. Moller, a tax refund for the years 1976 and 1977. 1 Cl.Ct. 25, 553 F.Supp. 1071 (1982). The Claims Court concluded that taxpayers were active investors engaged in the “trade or business” of making investments and held that taxpayers were entitled to deduct the expenses of two home offices under I.R.C. § 280A. For the reasons stated below, we reverse.
FACTS
Since 1965 taxpayers have relied almost entirely on the income derived from their investments for…
2Cases cited11 opinions
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Ralph E. Purvis and Patricia Lee Purvis, His Wife v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Fuld v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1943
- Levin v. United StatesUnited States Court of Claims · 1979
6 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Laureys v. CommissionerUnited States Tax Court · 1989
- Green v. Comm'rUnited States Tax Court · 1984
- King v. CommissionerUnited States Tax Court · 1987
- Robert P. Groetzinger v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1985
38 more not listed; retrieve them via the Exa API.