Forget what you know Keefe shows there’s no hope for dealer-investor jurisprudence Matthew E. Rappaport
By: Rappaport, Matthew E
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Material type: 
ArticlePublisher: 2021Subject(s): INVERSIONES EMPRESARIALES | IMPUESTOS | ESTADOS UNIDOS | JURISPRUDENCIA
In:
Journal of Taxation of Investments v. 38, n. 2, Winter 2021, p. 39-49Summary: The so-called “dealer-investor issue” requires courts to differentiate between property held for investment and property held primarily for sale in a taxpayer’s trade or business. The latest case examining the dealer-investor issue is Keefe, a Second Circuit taxpayer appeal of a Tax Court decision. Keefe is an atypical
“bad facts” case; the circumstances of the subject property might have favored the taxpayers, but the taxpayers’ failure to fi le income tax returns until receiving an IRS notice of intent to levy might have doomed their case from the beginning. The result for the tax community is two judicial opinions to further muddy
the waters of the dealer-investor issue, proving that litigating the subject is unpredictable and tax opinions are necessary whenever practitioners confront this type of matter.
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| Artículos | IEF | IEF | OP 235/2021/38/2-2 (Browse shelf) | Available | OP 235/2021/38/2-2 |
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| OP 235/2021/2 Journal of Taxation of Investments | OP 235/2021/3 Journal of Taxation of Investments | OP 235/2021/38/2-1 Parsing the final and proposed regulations under Section 163(j) | OP 235/2021/38/2-2 Forget what you know | OP 235/2021/38/2-3 Capital gains harvesting with changing tax rates | OP 235/2021/38/2-4 The application of sales tax in the U.S. and how It differs from Value Added Tax | OP 235/2021/38/2-5 A SALT cap workaround that works? |
Disponible también en formato electrónico.
Resumen.
The so-called “dealer-investor issue” requires courts to differentiate between property held for investment and property held primarily for sale in a taxpayer’s trade or business. The latest case examining the dealer-investor issue is Keefe, a Second Circuit taxpayer appeal of a Tax Court decision. Keefe is an atypical
“bad facts” case; the circumstances of the subject property might have favored the taxpayers, but the taxpayers’ failure to fi le income tax returns until receiving an IRS notice of intent to levy might have doomed their case from the beginning. The result for the tax community is two judicial opinions to further muddy
the waters of the dealer-investor issue, proving that litigating the subject is unpredictable and tax opinions are necessary whenever practitioners confront this type of matter.
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