Read and brief the following two cases. N.E. Soliman v. Commissioner, 113 S.Ct. 701; 93-1 USTC 50,014;
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N.E. Soliman v. Commissioner, 113 S.Ct. 701; 93-1 USTC ¶50,014; 71 AFTR2d 93-463
N.E. Soliman v. Commissioner, 935 F2d 52; 91-1 USTC ¶50,291; 67 AFTR2d 91-1112
a. Were the judges in the Supreme Court decision unanimous or split? How do you know?
b. What does Revenue Ruling 94-24, 1994-1 CB 87 add to your understanding of this Code provision and the Soliman case?
c. Read IRC §280A(c)(l)(A). Has Congress amended this provision since Soliman and the revenue ruling? In what way? How do the changes affect the authority of the Soliman case? Can you imagine factual situations in which Soliman might still apply?
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