Lenard L. Politte, M.D., Inc. v. Commissioner
United States Tax Court
Petitioner was required to change to a calendar tax year by secs. 441(i) and 444, I.R.C. To effect the change, petitioner was required to file an annualized return for a short tax period under sec. 443, I.R.C. It included in income its distributive share of certain partnership items, including guaranteed payments, without annualizing the amounts of these items.
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Petitioner was required to change to a calendar tax year by secs. 441(i) and 444, I.R.C. To effect the change, petitioner was required to file an annualized return for a short tax period under sec. 443, I.R.C. It included in income its distributive share of certain partnership items, including guaranteed payments, without annualizing the amounts of these items. Petitioner claimed that these items represented partnership activity over a 12-month period and therefore were not required to be annualized. Respondent determined that annualization of these items was required by sec. 443(b)(1) and (…
1Opinion of the Court
Lenard L. Politte, M.D., Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Lenard L. Politte, M.D., Inc. v. Commissioner
Docket No. 4012-92
United States Tax Court
101 T.C. 359; 1993 U.S. Tax Ct. LEXIS 65; 101 T.C. No. 24;
October 27, 1993, Filed
Decision will be entered under Rule 155.
Petitioner was required to change to a calendar tax year by secs. 441(i) and 444, I.R.C. To effect the change, petitioner was required to file an annualized return for a short tax period under sec. 443, I.R.C. It included in income its distributive share of certain partnership items, including…
2Cases cited6 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Miller v. CommissionerUnited States Tax Court · 1969
- Edward T. And Billie R. Pratt, William D. And Anita Pratt, Jack E. And Crystal A. Pratt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1977
- Pratt v. CommissionerUnited States Tax Court · 1975
- SPATOLS v. COMMISSIONERUnited States Board of Tax Appeals · 1941
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