Scott v. Commissioner
United States Tax Court
P, a college professor, also owned and managed five rental properties and operated a chemical analysis business. He used a separate structure located in his backyard as an office to carry on his rental and chemical businesses.
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P, a college professor, also owned and managed five rental properties and operated a chemical analysis business. He used a separate structure located in his backyard as an office to carry on his rental and chemical businesses. Held: 1. The separate structure used as an office was "appurtenant to" P's house and therefore constituted part of the dwelling unit for purposes of sec. 280A, I.R.C. 1954. 2. Sec. 280A(c)(5) limits the deductions allocable to the use of the separate structure to the gross income derived from such use; there is no requirement that such gross income be first reduced by…
1Opinion of the Court
Simpson, Judge-.
The Commissioner determined a deficiency of $7,923 in the petitioners’ Federal income taxes for 1980. After concessions by both parties, the issues for decision are: (1) Whether a separate structure which contained an office and which was on the same property as the petitioner’s house was "appurtenant to” such house within the meaning of section 280A(f)(1)(A), I.R.C. 19541 and therefore a part of their dwelling unit; and (2) how the gross income limitation of section 280(c)(5) is to be applied to the deductions attributable to the use of such office.
FINDINGS OF FACT
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2Cases cited14 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- United States v. CartwrightSupreme Court of the United States · 1973
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
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3Cited by30 opinions
- Estate of Howard v. CommissionerUnited States Tax Court · 1988
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- Freesen v. CommissionerUnited States Tax Court · 1985
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- North Ridge Country Club v. CommissionerUnited States Tax Court · 1987
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