Held: A trust can qualify for the I.R.C. sec. 469(c)(7) exception. A trust is capable of performing personal services within the meaning of I.R.C. sec. 469(c)(7). Services performed by individual trustees on behalf of the trust may be considered personal services performed by the trust.
Held, further, T materially participated in real-property trades or businesses.
Judge(s): Richard Morrison
Jurisdiction: U.S. Tax Court
Related Categories: Taxation
|Circuit Court Judge(s)|
|Petitioner Lawyer(s)||Petitioner Law Firm(s)|
|Respondent Lawyer(s)||Respondent Law Firm(s)|
|Brett Chmielewski||Internal Revenue Service|
|Meso Hammoud||Internal Revenue Service|