Logourl black
From our private database of 14,100+ case briefs...

Remuzzi v. Commissioner

United States Tax Court
T.C. Memo 1988-8 (1988)


Facts

In 1978, Dr. Robert Remuzzi and his wife (plaintiffs) purchased and moved to a large dilapidated farm for their personal pleasure and recreation. The Remuzzis had no farming experience. The farm was operated by Llewellyn Payne, a farmer who had no experience operating a large farm and had a heavy debt load. In return for operating the farm, Payne received several benefits and a substantial loan from the Remuzzis. Between 1978 and 1982, the Remuzzis lost an average of $32,000 on farm operations each year. However, over those five years, the Remuzzis had an average annual income from other sources of over $166,000 and received substantial tax benefits due to the farm. Over this time, Payne’s health had declined. Payne gradually became unable to operate the farm, and he eventually defaulted on the loan. The Remuzzis attributed their large losses to the costs of hiring a replacement for Payne and of absorbing Payne’s default. The Remuzzis claimed business-loss deductions in their 1981 and 1982 federal taxes. The commissioner of internal revenue (commissioner) (defendant) determined that the Remuzzis’ losses were not tax deductible, and disallowed the deductions. The Remuzzis petitioned the tax court for a redetermination.

Rule of Law

The rule of law is the black letter law upon which the court rested its decision.

To access this section, please start your free trial or log in.

Issue

The issue section includes the dispositive legal issue in the case phrased as a question.

To access this section, please start your free trial or log in.

Holding and Reasoning (Korner, J.)

The holding and reasoning section includes:

  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

To access this section, please start your free trial or log in.

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.

  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.

Here's why 217,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 14,100 briefs, keyed to 189 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.