Sicanoff Vegetable Oil Corp. v. Commissioner
United States Tax Court
Each of the petitioner corporations was engaged in the purchase and sale of commodities under contracts providing for "forward delivery," that were not made through or subject to the rules of a board of trade or commodity exchange. Neither corporation produced, processed, graded, stored, transported, or otherwise physically handled any of the commodities which it thus bought and sold.
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Each of the petitioner corporations was engaged in the purchase and sale of commodities under contracts providing for "forward delivery," that were not made through or subject to the rules of a board of trade or commodity exchange. Neither corporation produced, processed, graded, stored, transported, or otherwise physically handled any of the commodities which it thus bought and sold. Each corporation also engaged extensively in "futures" transactions in a wide variety of commodities, on or subject to the rules of a board of trade or commodity exchange. 1. Held, that each of the petitioners…
1Opinion of the Court
Pleece, Judge:
These cases, which were consolidated for trial, involve deficiencies in income tax and in personal holding company surtax, determined by the respondent as follows:
Docket No. 53637. Sicanoff Vegetable Oil Corporation
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All issues raised by the pleadings, except that pertaining to the determined deficiencies in personal holding company surtax, have been settled by stipulations of the parties; and, accordingly, the sole remaining issue for decision is whether each of the petitioner corporations, during its fiscal years involved, was a personal holding company within the…
2Cases cited12 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- United States v. New York Coffee & Sugar Exchange, Inc.Supreme Court of the United States · 1924
- Commissioner of Internal Rev. v. Farmers & G C. Oil Co.Court of Appeals for the Fifth Circuit · 1941
- Corn Products Refining Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Corn Products Refining Co. v. CommissionerUnited States Tax Court · 1951
7 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
- Smith v. CommissionerUnited States Tax Court · 1982
- Frentz v. CommissionerUnited States Tax Court · 1965
- Estate of Mandels v. CommissionerUnited States Tax Court · 1975
- Rollert Residuary Trust v. CommissionerUnited States Tax Court · 1983
- Muldrow v. CommissionerUnited States Tax Court · 1962
49 more not listed; retrieve them via the Exa API.