Epstein v. Commissioner
United States Tax Court
On their 1988 tax return, Ps, a husband and wife, claimed various Schedule C deductions with respect to a venture carried on by petitioner wife. Ps also claimed Schedule E losses with respect to two rental properties they owned: a condominium and a vacation house.
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On their 1988 tax return, Ps, a husband and wife, claimed various Schedule C deductions with respect to a venture carried on by petitioner wife. Ps also claimed Schedule E losses with respect to two rental properties they owned: a condominium and a vacation house. They also claimed Schedule E losses incurred in their dealings with an entity known as Friedmann Financial Company #2 (Friedmann). R disallowed all of Ps' reported Schedule C deductions and Schedule E loss deductions. 1. Held: Ps' Schedule C activity was not engaged in for profit within the meaning of sec. 183, I.R.C. 2. Held,…
1Opinion of the Court
JERALD EPSTEIN AND CAREN EPSTEIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Epstein v. Commissioner
Docket No. 28060-91
United States Tax Court
T.C. Memo 1994-34; 1994 Tax Ct. Memo LEXIS 33; 67 T.C.M. (CCH) 2046;
January 26, 1994, Filed
On their 1988 tax return, Ps, a husband and wife, claimed various Schedule C deductions with respect to a venture carried on by petitioner wife. Ps also claimed Schedule E losses with respect to two rental properties they owned: a condominium and a vacation house. They also claimed Schedule E losses incurred in their dealings with an entity known…
2Cases cited15 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Dunn v. CommissionerUnited States Tax Court · 1978
- Recklitis v. CommissionerUnited States Tax Court · 1988
- Herbert A. Dunn and Georgia E. Dunn v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1980
10 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- FRIEDMANN v. COMMISSIONERUnited States Tax Court · 2001
- DiDonato v. Comm'rUnited States Tax Court · 2013
- Lattin v. CommissionerUnited States Tax Court · 1995