Legal Opinion

Broz v. Comm'r

United States Tax Court

Decided September 1, 2011No. Docket No. 21629-06Published

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

  1. Heckler v. Community Health Services of Crawford County, Inc.Supreme Court of the United States · 1984
  2. Lexecon Inc. v. Milberg Weiss Bershad Hynes & LerachSupreme Court of the United States · 1998
  3. Tokarski v. CommissionerUnited States Tax Court · 1986
  4. Commissioner v. GroetzingerSupreme Court of the United States · 1987
  5. Putnam v. CommissionerSupreme Court of the United States · 1956

43 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API