Legal Opinion

Scott v. Commissioner

United States Tax Court

Decided April 15, 1985No. Docket No. 18916-82Published

P, a college professor, also owned and managed five rental properties and operated a chemical analysis business. He used a separate structure located in his backyard as an office to carry on his rental and chemical businesses.

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P, a college professor, also owned and managed five rental properties and operated a chemical analysis business. He used a separate structure located in his backyard as an office to carry on his rental and chemical businesses. Held: 1. The separate structure used as an office was "appurtenant to" P's house and therefore constituted part of the dwelling unit for purposes of sec. 280A, I.R.C. 1954. 2. Sec. 280A(c)(5) limits the deductions allocable to the use of the separate structure to the gross income derived from such use; there is no requirement that such gross income be first reduced by…

1Opinion of the Court

Charles A. Scott and Jan F. Scott, Petitioners v. Commissioner of Internal Revenue, Respondent

Scott v. Commissioner

Docket No. 18916-82

United States Tax Court

84 T.C. 683; 1985 U.S. Tax Ct. LEXIS 90; 84 T.C. No. 45;

April 15, 1985. April 15, 1985, Filed

Decision will be entered under Rule 155.

P, a college professor, also owned and managed five rental properties and operated a chemical analysis business. He used a separate structure located in his backyard as an office to carry on his rental and chemical businesses. Held:

1. The separate structure used as an office was "appurtenant to" P's house…

2Cases cited15 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. Bingler v. JohnsonSupreme Court of the United States · 1969
  4. United States v. CartwrightSupreme Court of the United States · 1973
  5. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979

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