Sidell v. Commissioner
United States Tax Court
Respondent recharacterized the income petitioner husband received from the rental of property to his wholly owned C corporation from passive to nonpassive, pursuant to the attribution rule of sec. 1.469-4(a), Income Tax Regs., and the so-called self-rented property rule contained in sec. 1.469- 2(f)(6), Income Tax Regs.
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Respondent recharacterized the income petitioner husband received from the rental of property to his wholly owned C corporation from passive to nonpassive, pursuant to the attribution rule of sec. 1.469-4(a), Income Tax Regs., and the so-called self-rented property rule contained in sec. 1.469- 2(f)(6), Income Tax Regs. As a consequence of this recharacterization, petitioners were able neither to reduce such rental income by losses from other rental properties nor to use certain rehabilitation credits. 1. HELD: Pursuant to sec. 469(l), I.R.C., the Secretary properly promulgated the…
1Opinion of the Court
CHESTER F. AND FAYE L. SIDELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sidell v. Commissioner
No. 10489-98
United States Tax Court
T.C. Memo 1999-301; 1999 Tax Ct. Memo LEXIS 347; 78 T.C.M. (CCH) 423;
September 4, 1999, Filed
Decision with respect to the deficiencies for 1993 and 1994 will be entered for respondent; decision with respect to the accuracy-related penalty under section 6662(a) with respect to 1994 will be entered for petitioners.
Respondent recharacterized the income petitioner husband
received from the rental of property to his wholly owned C
corporation from passive…
2Cases cited17 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
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3Cited by3 opinions
- Sidell v. CommissionerCourt of Appeals for the First Circuit · 2000
- Michael F. Connor and Jane H. Connor v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2000
- Krukowski v. CommissionerUnited States Tax Court · 2000