Casel v. Commissioner
United States Tax Court
Held, sec. 1.267(b)-1(b)(1) and (2), Income Tax Regs., which, in part, provides that a transaction described in sec. 267(a), I.R.C. 1954, between a partnership and a person other than a partner shall be considered as occurring between the other person and the members of the partnership separately, is valid.
Read the full summary
Held, sec. 1.267(b)-1(b)(1) and (2), Income Tax Regs., which, in part, provides that a transaction described in sec. 267(a), I.R.C. 1954, between a partnership and a person other than a partner shall be considered as occurring between the other person and the members of the partnership separately, is valid. Held, further, petitioners may not deduct taxes and interest paid with respect to real estate to the extent that such taxes and interest accrued prior to the date that taxpayers acquired an interest in the property.
1Opinion of the Court
Wiles, Judge-.
Respondent determined deficiencies in petitioners’ 1974 and 1975 Federal income taxes of $4,202.37 and $10,390.96, respectively. The issues for decision are: (1) Whether petitioner Edward Casel’s distributive share of his partnership loss for 1974 and 1975 should be reduced pursuant to section 2671 to the extent of the unpaid management fees owed by the partnership to a related corporation that were accrued and deducted by the partnership in computing its losses for those years; (2) whether petitioners are entitled to a claimed deduction for 1975 for payment of back real estate…
2Cases cited17 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- South Texas Rice Warehouse Co. v. CommissionerUnited States Tax Court · 1965
- Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
- World Airways, Inc. v. CommissionerUnited States Tax Court · 1974
12 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Bennett v. CommissionerUnited States Tax Court · 1982
- Coggin Automotive Corporation v. Comr. of IRSCourt of Appeals for the Eleventh Circuit · 2002
- P.D.B. Sports v. CommissionerUnited States Tax Court · 1997
- Brown Group v. CommissionerUnited States Tax Court · 1995
- Coggin Auto. Corp. v. CommissionerUnited States Tax Court · 2000
13 more not listed; retrieve them via the Exa API.