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HILLMAN v. COMMISSIONER

Docket No. 19893-97.

118 T.C. 323 (2002)

118 T.C. No. 17

DAVID H. AND SUZANNE HILLMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE RESPONDENT

United States Tax Court.

Filed April 9, 2002.

Attorney(s) appearing for the Case

Stefan F. Tucker, for petitioners.

Wilton A. Baker, for respondent.

SUPPLEMENTAL OPINION

GERBER, Judge:

In an earlier Opinion filed by the Court in this case we decided that petitioners were entitled to treat management fees as offsetting self-charged items for purposes of section 469.1 The Court of Appeals for the Fourth Circuit disagreed and reversed our holding. Hillman v. Commissioner, 263 F.3d 338 (4th Cir. 2001), revg. 114 T...

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