Legal Opinion

Powell v. Commissioner

United States Tax Court

Decided June 10, 1980No. Docket No. 9750-79Published

Petitioners took legal title to their new principal residence on Feb. 21, 1975, but they did not occupy their residence until Mar. 22, 1975. Held, petitioners are not entitled to a credit under sec. 44, I.R.C. 1954, as amended, since they did not acquire their new principal residence within the time prescribed by sec. 44(e)(1)(B), I.R.C. 1954, as amended.

1Opinion of the Court

Robert L. Powell III and Belva H. Powell, Petitioners v. Commissioner of Internal Revenue, Respondent

Powell v. Commissioner

Docket No. 9750-79

United States Tax Court

74 T.C. 552; 1980 U.S. Tax Ct. LEXIS 115;

June 10, 1980, Filed

Decision will be entered for the respondent.

Petitioners took legal title to their new principal residence on Feb. 21, 1975, but they did not occupy their residence until Mar. 22, 1975. Held, petitioners are not entitled to a credit under sec. 44, I.R.C. 1954, as amended, since they did not acquire their new principal residence within the time prescribed by sec.…

2Cases cited3 opinions

  1. Shaw v. CommissionerUnited States Tax Court · 1978
  2. Dobin v. CommissionerUnited States Tax Court · 1980
  3. Powell v. CommissionerUnited States Tax Court · 1980

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