Allen Machinery Corp. v. Commissioner
United States Tax Court
Income was received by petitioner during the years in issue pursuant to two service contracts with another corporation. Held, that the second of the two contracts involved designated the president of petitioner personally to perform services, and therefore the income received thereunder during the taxable year ended January 31, 1954, was personal holding company income under section 502 (e), I. R. C. 1939. General Management Corporation, 46 B. T. A. 738, followed.
1Opinion of the Court
Withey, Judge:
The respondent determined deficiencies in petitioner’s personal holding company surtax for the years and in the amounts as follows:
Fiscal year ended January si Deficiency
1952-$9, 506.40
1953- 12,117.61
1954- 12, 687.65
The issue presented for our decision is the correctness of the respondent’s action in determining that at least 80 per cent of the petitioner’s gross income for the taxable years ended January 31, 1952, January 31, 1953, and January 31, 1954, constitutes personal holding company income within the meaning of section 502 (e) of the Internal Revenue Code of 1939 so as…
2Cases cited1 opinion
- General Management Corp. v. COM'R OF INT. REVENUECourt of Appeals for the Seventh Circuit · 1943
3Cited by8 opinions
- Kurt Frings Agency, Inc. v. CommissionerUnited States Tax Court · 1964
- Claggett v. CommissionerUnited States Tax Court · 1965
- Thomas P. Byrnes, Inc. v. CommissionerUnited States Tax Court · 1979
- Morrison v. CommissionerUnited States Tax Court · 1982
- Allen Machinery Corp. v. CommissionerUnited States Tax Court · 1958
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