Legal Opinion

Rink v. Commissioner

United States Tax Court

Decided February 10, 1969No. Docket No. 2643-67PublishedCited by 60 opinions

1. The petitioner paid certain personal property taxes and filing fees on behalf of a corporation (not a subch. S corporation) in which he owned 95 percent of the issued and outstanding stock. Held, the petitioner may not deduct such payments on his personal income tax return. 2. Property owned by the corporation suffered damage due to vandalism.

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1. The petitioner paid certain personal property taxes and filing fees on behalf of a corporation (not a subch. S corporation) in which he owned 95 percent of the issued and outstanding stock. Held, the petitioner may not deduct such payments on his personal income tax return. 2. Property owned by the corporation suffered damage due to vandalism. Held, the petitioner is not entitled to a deduction, either as depreciation or as a casualty or business loss, on account of such damage on his personal return. 3. Held, the petitioner has failed to prove that he is entitled to a deduction for the…

1Opinion of the Court

SimpsoN, Judge:

The respondent determined deficiencies in the petitioners’ income tax in the amount of $443.77 for the taxable year ended December 31, 1964, and $436.92 for the taxable year ended December 31, 1965. Several issues have been settled by agreement of the parties; there remain for our decision the following issues:(1) May the petitioners deduct on their individual income tax returns personal property taxes and other expenses paid by them on behalf of a corporation of which they own substantially all the outstanding stock?(2) May the petitioners deduct on their individual income tax…

2Cases cited13 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  3. Lohrke v. CommissionerUnited States Tax Court · 1967
  4. Weigman v. CommissionerUnited States Tax Court · 1967
  5. Hunter v. CommissionerUnited States Tax Court · 1966

8 more not listed; retrieve them via the Exa API.

3Cited by60 opinions

  1. Fausner v. CommissionerUnited States Tax Court · 1971
  2. Gantner v. CommissionerUnited States Tax Court · 1988
  3. Grant v. CommissionerUnited States Tax Court · 1985
  4. Noel Tancred Escofil v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1972
  5. Craft v. Comm'rUnited States Tax Court · 2005

55 more not listed; retrieve them via the Exa API.

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