- 2 - sec. 62(a)(4), I.R.C., in computing Ps' adjusted gross income. Held, further, State nonresident income taxes are not deductible as a trade or business expense under sec. 62(a)(1), I.R.C. Tanner v. Commissioner, 45 T.C. 145 (1965), affd. per curiam 363 F.2d 36 (4th Cir. 1966), followed. L. Robert LeGoy, Jr. and Kurt O. Hunsberger, for petitioners. Paul L. Dixon, for respondent. OPINION PARR, Judge: Respondent determined deficiencies of $3,955, $5,379, and $3,983 in petitioners' Federal income taxes for the taxable years 1993, 1994, and 1995, respectively. The sole issue for decision is whether State nonresident income taxes paid on net royalty income are deductible for purposes of determining adjusted gross income. We hold they are not. Background This case was submitted fully stipulated under Rule 122.1 The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners resided in 1Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code in effect for the taxable years at issue.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011