Omaha Aircraft Leasing Co. v. Commissioner of Internal Revenue

The question in this case is whether Omaha Aircraft Leasing Co. was, during the tax years 1973, 1974, and 1975, engaged in “the active and regular conduct of a lending or finance business” within the meaning of Section 542(c)(6)(A) of the Internal Revenue Code, 26 U.S.C. § 542(c)(6)(A), and therefore exempt from the personal-holding-company tax imposed by Section 541 of the Code, 26 U.S.C. § 541. The Tax Court, 74 T.C. 251 (1980), held that the appellant taxpayer was not so engaged.

We affirm, substantially for the reasons stated in Judge Hall’s opinion for the Tax Court. Taxpayer argues,…