Legal Opinion

Patrick J. Wachter & Louise M. Wachter v. Commissioner

United States Tax Court

Decided March 11, 2014No. 9213-11, 9219-11Published

1Opinion of the Court

142 T.C. No. 7

UNITED STATES TAX COURT PATRICK J. WACHTER AND LOUISE M. WACHTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent MICHAEL E. WACHTER AND KELLY A. WACHTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9213-11, 9219-11. Filed March 11, 2014. For 2004 through 2006 Ps reported charitable contributions that flowed to them from a partnership and an LLC, both of which were treated as partnerships for tax purposes. For each year the LLC reported charitable contributions of cash and the partnership reported bargain sales of conservation easements as…

2Cases cited19 opinions

  1. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  2. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  3. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
  4. United States v. National Bank of CommerceSupreme Court of the United States · 1985
  5. Naftel v. CommissionerUnited States Tax Court · 1985

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