Kurt Frings Agency, Inc. v. Commissioner
United States Tax Court
Petitioner is a corporation organized for the purpose of representing actors, writers, producers and directors as the artists' manager. Each contract executed between petitioner and the various artists designated "Kurt Frings" to be the person required to personally supervise the artists' business. All of petitioner's income was derived from commissions received pursuant to these contracts. Kurt Frings owned 100% of petitioner's stock.
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Petitioner is a corporation organized for the purpose of representing actors, writers, producers and directors as the artists' manager. Each contract executed between petitioner and the various artists designated "Kurt Frings" to be the person required to personally supervise the artists' business. All of petitioner's income was derived from commissions received pursuant to these contracts. Kurt Frings owned 100% of petitioner's stock. Held: The income received by petitioner during all the years in issue was "personal holding company income" within the meaning of section 543(a)(5), I.R.C.…
1Opinion of the Court
Fax, Judge:
The Commissioner determined deficiencies in petitioner’s income tax as follows:
Fiscal year ended Jan. 31— Deficiency
1957_ $19, 584. 68
1958_ 19, 611. 14
1959_ 28, 637. 54
1960_ 25, 120. 38
The only issue for decision1 is whether or not the petitioner was subject to the personal holding company tax imposed by section 5412 for any or all of the years involved herein.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulation of facts, together with the exhibits attached thereto, is incorporated herein by this reference.
Petitioner, Kurt Frings Agency, Inc., is a California…
2Cases cited9 opinions
- Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
- Turnbow v. CommissionerSupreme Court of the United States · 1961
- Cedarburg Canning Co. v. Commissioner of Int. Rev.Court of Appeals for the Seventh Circuit · 1945
- American Package Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1942
- Sebago Lumber Co. v. CommissionerUnited States Tax Court · 1956
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3Cited by15 opinions
- Montgomery Coca-Cola Bottling Co. v. United StatesUnited States Court of Claims · 1980
- Kenyatta Corp. v. CommissionerUnited States Tax Court · 1986
- Claggett v. CommissionerUnited States Tax Court · 1965
- Darrow v. CommissionerUnited States Tax Court · 1975
- Thomas P. Byrnes, Inc. v. CommissionerUnited States Tax Court · 1979
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