Sherwood v. Commissioner
United States Tax Court
In furtherance of their farming activities, Ps constructed a barn, acquired and constructed various properties and improvements, incurred land clearing and contouring costs, and planted 45 almond trees. Ps also "donated" approximately 50 percent of their earnings to a charter of the Universal Life Church. Held, Ps' barn was not section 38 property.
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In furtherance of their farming activities, Ps constructed a barn, acquired and constructed various properties and improvements, incurred land clearing and contouring costs, and planted 45 almond trees. Ps also "donated" approximately 50 percent of their earnings to a charter of the Universal Life Church. Held, Ps' barn was not section 38 property. Held further, Ps failed to establish that unclaimed ITC attributable to property placed in service in prior years was currently available for use as a carryover. Held further, an irrigation pipe installed by Ps does not constitute a section 175…
1Opinion of the Court
RAYMOND B. SHERWOOD AND BEVERLY SHERWOOD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sherwood v. Commissioner
Docket No. 12018-84.
United States Tax Court
T.C. Memo 1988-544; 1988 Tax Ct. Memo LEXIS 573; 56 T.C.M. (CCH) 735; T.C.M. (RIA) 88544;
November 29, 1988
In furtherance of their farming activities, Ps constructed a barn, acquired and constructed various properties and improvements, incurred land clearing and contouring costs, and planted 45 almond trees. Ps also "donated" approximately 50 percent of their earnings to a charter of the Universal Life Church. Held, Ps' barn was…
2Cases cited24 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Roberts v. CommissionerUnited States Tax Court · 1974
- Cullinan v. Walker, Collector of Internal RevenueSupreme Court of the United States · 1923
- A. Raymond Jones and Mary Lou Jones, Husband and Wife v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
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