Legal Opinion

Mayflower Inv. Co. v. Commissioner

United States Tax Court

Decided July 21, 1955No. Docket No. 48006Published

1 Personal Holding Company Income -- Interest or Profit -- Sec. 502 (a). -- The face amount of a note in excess of the sum loaned thereon constituted interest within the meaning of section 502 (a) of the Internal Revenue Code of 1939 and was not a share of the profits on a transaction for which the loan was given. 2. Failure to File Returns -- Reasonable Cause v. Willful Neglect -- Persons Consulted. -- Failure of a corporation to file personal holding company tax returns…

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1 Personal Holding Company Income -- Interest or Profit -- Sec. 502 (a). -- The face amount of a note in excess of the sum loaned thereon constituted interest within the meaning of section 502 (a) of the Internal Revenue Code of 1939 and was not a share of the profits on a transaction for which the loan was given. 2. Failure to File Returns -- Reasonable Cause v. Willful Neglect -- Persons Consulted. -- Failure of a corporation to file personal holding company tax returns for 6 years in reliance upon the advice and actions of its secretary-bookkeeper who discussed profit and loss with an…

1Opinion of the Court

Mayflower Investment Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Mayflower Inv. Co. v. Commissioner

Docket No. 48006

United States Tax Court

24 T.C. 729; 1955 U.S. Tax Ct. LEXIS 136;

July 21, 1955, Filed

Decision will be entered for the respondent.

1 Personal Holding Company Income -- Interest or Profit -- Sec. 502 (a). -- The face amount of a note in excess of the sum loaned thereon constituted interest within the meaning of section 502 (a) of the Internal Revenue Code of 1939 and was not a share of the profits on a transaction for which the loan was given.

2. Failure to…

2Cases cited9 opinions

  1. Southeastern Finance Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
  2. Southeastern Finance Co. v. CommissionerUnited States Tax Court · 1945
  3. Tarbox Corp. v. CommissionerUnited States Tax Court · 1946
  4. R. Simpson & Co. v. CommissionerSupreme Court of the United States · 1944
  5. Hermax Co. v. CommissionerUnited States Tax Court · 1948

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