When is a rental property not a rental property?

In Krutkowski (114 TC 25), the Tax Court concurred with the IRS's determination that rental income received by the sole shareholder of a C corporation from his corporation was nonpassive and could not be offset by other passive losses. The result is that a "rental" activity provided t...

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Bibliographic Details
Published in:The Tax Adviser 2000-10, Vol.31 (10), p.700
Main Author: Moore, Philip E
Format: Magazinearticle
Language:English
Subjects:
114 TC 25
C corporations
Corporations
Fair value
Income taxes
Joint ventures
Law firms
Laws, regulations and rules
Passive activity
Passive activity (Taxation)
Rentals
Rents (Property)
Stockholders
Tax court decisions
Tax courts
Tax deductions
Taxation
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Summary:In Krutkowski (114 TC 25), the Tax Court concurred with the IRS's determination that rental income received by the sole shareholder of a C corporation from his corporation was nonpassive and could not be offset by other passive losses. The result is that a "rental" activity provided to a 100%-owned passthrough entity that generates a loss will be reclassified as a nonpassive activity.
ISSN:0039-9957