Legal Opinion
Thomas P. Krukowski and Ermina A. Krukowski v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided February 5, 2002No. 00-3946PublishedCited by 18 opinions
1Opinion of the Court
KANNE, Circuit Judge.
In 1994, the Commissioner of the Internal Revenue Service issued a deficiency notice to Thomas and Ermina Krukowski. The notice informed the Krukowskis that they had misclassified certain rental income as passive income on their 1994 federal income tax return. The Krukowskis challenged the deficiency charge, but the Tax Court granted summary judgment in favor of the Commissioner. On appeal, the Krukowskis argue (1) that they are entitled to characterize the particular rental activity as a passive activity, (2) that the Secretary of the Treasury’s regulation…
2Cases cited10 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Whitman v. American Trucking Assns., Inc.Supreme Court of the United States · 2001
- Sidell v. CommissionerCourt of Appeals for the First Circuit · 2000
- Sheppard v. RosenkransWisconsin Supreme Court · 1901
- A. Remy Fransen, Jr., and Eugenie B. Fransen v. United StatesCourt of Appeals for the Fifth Circuit · 1999
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3Cited by18 opinions
- David and Lynette Kindred v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2006
- Billion v. Commissioner of RevenueSupreme Court of Minnesota · 2013
- Carlos v. Comm'rUnited States Tax Court · 2004
- Adeyemo v. Comm'rUnited States Tax Court · 2014
- Gary Beecher Delores Beecher v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2007
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