Coldwater Seafood Corp. v. Commissioner
United States Tax Court
Held, certain payments made from Jan. 1, 1963, through Apr. 25, 1969, by petitioner to its parent corporation in Iceland were interest within the meaning of secs. 1441 and 1442, I.R.C. 1954, and petitioner is liable for the 30-percent tax which it failed to withhold on such payments.
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Held, certain payments made from Jan. 1, 1963, through Apr. 25, 1969, by petitioner to its parent corporation in Iceland were interest within the meaning of secs. 1441 and 1442, I.R.C. 1954, and petitioner is liable for the 30-percent tax which it failed to withhold on such payments. Held, further, petitioner's failure to withhold tax and file returns in respect of such payments was due to reasonable cause and not to willful neglect within the meaning of sec. 6651(a), I.R.C. 1954.
1Opinion of the Court
Coldwater Seafood Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Coldwater Seafood Corp. v. Commissioner
Docket No. 8244-74
United States Tax Court
69 T.C. 966; 1978 U.S. Tax Ct. LEXIS 152;
March 21, 1978, Filed
Decision will be entered under Rule 155.
Held, certain payments made from Jan. 1, 1963, through Apr. 25, 1969, by petitioner to its parent corporation in Iceland were interest within the meaning of secs. 1441 and 1442, I.R.C. 1954, and petitioner is liable for the 30-percent tax which it failed to withhold on such payments. Held, further, petitioner's failure to…
2Cases cited8 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- D. Loveman & Son Export Corp. v. CommissionerUnited States Tax Court · 1960
- Groves v. CommissionerUnited States Board of Tax Appeals · 1938
- Coldwater Seafood Corp. v. CommissionerUnited States Tax Court · 1978
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