Byers v. Commissioner
United States Tax Court
Petitioners purchased two condominium units in a complex operated by a limited partnership as a resort hotel. Petitioners were also required to become limited partners in the partnership and to make their units available to a rental pool for rental to hotel guests for the entire year except for up to 30 days' personal use rent free.
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Petitioners purchased two condominium units in a complex operated by a limited partnership as a resort hotel. Petitioners were also required to become limited partners in the partnership and to make their units available to a rental pool for rental to hotel guests for the entire year except for up to 30 days' personal use rent free. Held, petitioners' units were not "used exclusively as a hotel" within the meaning of sec. 280A(f)(1)(B), I.R.C. 1954. Held, further, petitioners' units were only rented at fair rental those days the units were actually rented to hotel guests. Held, further, the…
1Opinion of the Court
Kenneth G. Byers, Jr., and Nedra Byers, Petitioners v. Commissioner of Internal Revenue, Respondent
Byers v. Commissioner
Docket No. 18945-80
United States Tax Court
82 T.C. 919; 1984 U.S. Tax Ct. LEXIS 60; 82 T.C. No. 69;
June 5, 1984, Filed
Decision will be entered under Rule 155.
Petitioners purchased two condominium units in a complex operated by a limited partnership as a resort hotel. Petitioners were also required to become limited partners in the partnership and to make their units available to a rental pool for rental to hotel guests for the entire year except for up to 30 days' personal…
2Cases cited9 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Crane v. CommissionerSupreme Court of the United States · 1947
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Bolton v. CommissionerUnited States Tax Court · 1981
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