Louismet v. Commissioner
United States Tax Court
Petitioners purchased a jet in July 1974. They also decided to go into the commodities trading business. They became 50-percent stockholders in a trading corporation and agreed to lease their jet to the corporation.
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Petitioners purchased a jet in July 1974. They also decided to go into the commodities trading business. They became 50-percent stockholders in a trading corporation and agreed to lease their jet to the corporation. Held, petitioners were engaged in the air charter business and commodities trading business for profit in 1974. Sec. 183, I.R.C. 1954. Held further, expenses incurred by petitioners with respect to use of the jet by the corporation were not loans to the corporation but were deductible as business expenses. Sec. 162. Held further, the commodities trading business did not commence…
1Opinion of the Court
GENE E. LOUISMET AND LEATRICE LOUISMET, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Louismet v. Commissioner
Docket No. 14936-79.
United States Tax Court
T.C. Memo 1982-294; 1982 Tax Ct. Memo LEXIS 452; 43 T.C.M. (CCH) 1496; T.C.M. (RIA) 82294;
May 26, 1982.
Petitioners purchased a jet in July 1974. They also decided to go into the commodities trading business. They became 50-percent stockholders in a trading corporation and agreed to lease their jet to the corporation. Held, petitioners were engaged in the air charter business and commodities trading business for profit in 1974.…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Golanty v. CommissionerUnited States Tax Court · 1979
- Engdahl v. CommissionerUnited States Tax Court · 1979
- United States v. GeneresSupreme Court of the United States · 1972
- Allen v. CommissionerUnited States Tax Court · 1979
22 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
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- Donald R. Campbell and Patricia A. Campbell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Donald R. Campbell and Patricia A. Campbell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989