Broz v. Comm'r
United States Tax Court
Ps were shareholders in a wholly owned S corporation (S) engaged in providing wireless cellular service. S acquired wireless cellular licenses from the FCC and built networks to service the license areas. S never operated any on-air networks. Instead, P formed related holding companies to hold title to the licenses and equipment. Many issues raised questions of first impression because transactions were structured in this ever-changing technology industry.
Read the full summary
Ps were shareholders in a wholly owned S corporation (S) engaged in providing wireless cellular service. S acquired wireless cellular licenses from the FCC and built networks to service the license areas. S never operated any on-air networks. Instead, P formed related holding companies to hold title to the licenses and equipment. Many issues raised questions of first impression because transactions were structured in this ever-changing technology industry. Our holdings on these issues include: 1. Held: Ps were not sufficiently at risk for sec. 465, I.R.C., purposes when stock of a related…
1Opinion of the Court
ROBERT AND KIMBERLY BROZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Broz v. Comm'r
Docket No. 21629-06.
United States Tax Court
137 T.C. 46; 2011 U.S. Tax Ct. LEXIS 37;
September 1, 2011, Filed
Broz v. Comm'r, 137 T.C. 25, 2011 U.S. Tax Ct. LEXIS 35 (2011)
Decision will be entered under Rule 155.
Ps were shareholders in a wholly owned S corporation (S) engaged in providing wireless cellular service. S acquired wireless cellular licenses from the FCC and built networks to service the license areas. S never operated any on-air networks. Instead, P formed related holding companies to…
2Cases cited48 opinions
- Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
- Lexecon Inc. v. Milberg Weiss Bershad Hynes & LerachSupreme Court of the United States · 1998
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Putnam v. CommissionerSupreme Court of the United States · 1956
43 more not listed; retrieve them via the Exa API.