Dirico v. Comm'r
United States Tax Court
P-H leased land and telecommunication towers to S, his wholly owned S corporation, in exchange for a percentage of S's revenues from its leases of tower access to third parties. P-H also leased three parcels of land to S that were without towers. S also sold and serviced radios and provided specialized mobile radio (SMR) services to customers for a monthly subscriber fee.
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P-H leased land and telecommunication towers to S, his wholly owned S corporation, in exchange for a percentage of S's revenues from its leases of tower access to third parties. P-H also leased three parcels of land to S that were without towers. S also sold and serviced radios and provided specialized mobile radio (SMR) services to customers for a monthly subscriber fee. Four of the towers leased to S housed antennas in free (unused) space for the rent-free use of S's SMR customers. P-H reported the net income from his leases to S as passive activity rental income pursuant to I.R.C. sec.…
1Opinion of the Court
FRANCIS J. DIRICO AND JENNIFER DIRICO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Dirico v. Comm'r
Docket No. 16202-09.
United States Tax Court
139 T.C. 396; 2012 U.S. Tax Ct. LEXIS 42; 139 T.C. No. 16;
November 13, 2012, Filed
Decision will be entered under Rule 155.
P-H leased land and telecommunication towers to S, his wholly owned S corporation, in exchange for a percentage of S's revenues from its leases of tower access to third parties. P-H also leased three parcels of land to S that were without towers. S also sold and serviced radios and provided specialized mobile radio…
2Cases cited11 opinions
- Seligman v. CommissionerUnited States Tax Court · 1985
- Concord Consumers Hous. Coop. v. CommissionerUnited States Tax Court · 1987
- Sidell v. CommissionerCourt of Appeals for the First Circuit · 2000
- Ware v. CommissionerUnited States Tax Court · 1989
- R. Timmis Ware and Catherine K. Ware v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1990
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