Ireland v. Commissioner
United States Tax Court
Petitioners resided in East Lansing, Michigan, where petitioner-husband, Thomas, was a stockbroker. They purchased 3 acres of beach front property near Northport, Michigan, on West Grand Traverse Bay. There were three buildings, containing living accommodations, on the property. The property is located approximately 200 miles from Lansing. Thomas held various meetings with business associates at the property, which typically lasted several days.
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Petitioners resided in East Lansing, Michigan, where petitioner-husband, Thomas, was a stockbroker. They purchased 3 acres of beach front property near Northport, Michigan, on West Grand Traverse Bay. There were three buildings, containing living accommodations, on the property. The property is located approximately 200 miles from Lansing. Thomas held various meetings with business associates at the property, which typically lasted several days. On occasion, the families of the business associates accompanied them. Petitioners and their family did not take a vacation at the Northport property…
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined a deficiency-in petitioners’ Federal income tax for the taxable year 1981 in the amount of $9,722.96. The Commissioner also determined an addition to tax under section 6653(a)(1)2 in the amount of $1,298.79 and an addition to tax under section 6653(a)(2) in an amount equal to 50 percent of the interest due on $9,722.96.
After concessions,3 the issues for decision are: (1) Whether petitioners’ Northport property was a facility used in connection with an activity generally considered to constitute entertainment, amusement, or recreation within the meaning…
2Cases cited5 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Bixby v. CommissionerUnited States Tax Court · 1972
- Walliser v. CommissionerUnited States Tax Court · 1979
- Heineman v. CommissionerUnited States Tax Court · 1984
- Harrigan Lumber Co. v. CommissionerUnited States Tax Court · 1987
3Cited by9 opinions
- Hill v. Comm'rUnited States Tax Court · 2010
- Dodd v. CommissionerUnited States Tax Court · 1992
- Worden v. CommissionerUnited States Tax Court · 1992
- Damon R. Becnel v. CommissionerUnited States Tax Court · 2018
- French v. CommissionerUnited States Tax Court · 1990
4 more not listed; retrieve them via the Exa API.