Medical-Surgical Group, Inc. v. Commissioner
United States Tax Court
Personal Holding Company Income -- Sec. 502(f), I.R.C. 1939. -- Nine doctors and one dentist formed corporation to construct building for use as doctors' offices and related uses, each subscribing to one-tenth of the total stock outstanding. The nine doctor-stockholders also formed a partnership to conduct an X-ray and medical laboratory in the building.
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Personal Holding Company Income -- Sec. 502(f), I.R.C. 1939. -- Nine doctors and one dentist formed corporation to construct building for use as doctors' offices and related uses, each subscribing to one-tenth of the total stock outstanding. The nine doctor-stockholders also formed a partnership to conduct an X-ray and medical laboratory in the building. The gross income of the corporation consisted of a small amount of interest plus rent from a pharmacy operated by a nonstockholder, from the dentist-stockholder who was not a partner, from the partnership, and from each of the nine…
1Opinion of the Court
OPINION.
Drennen, Judge:
The taxes in controversy are personal holding company surtaxes. Respondent determined that petitioner was a personal holding company as defined by section 501(a), I.R.C. 1939, in each of the years 1947 throitgh 1953 and determined deficiencies in personal holding company surtaxes as follows:
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Petitioner denies that it was a personal holding company in the years involved. The amounts are not in dispute.
The facts were all stipulated and the stipulation of facts with exhibits attached are incorporated herein by this reference.
Petitioner was, at all times…
2Cases cited12 opinions
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Abbott v. CommissionerUnited States Tax Court · 1957
- Randolph Products Co. v. ManningCourt of Appeals for the Third Circuit · 1949
- Western Transmission Corp. v. CommissionerUnited States Tax Court · 1952
7 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1985
- Montgomery Coca-Cola Bottling Co.United States Court of Claims · 1975
- Medical-Surgical Group, Inc. v. CommissionerUnited States Tax Court · 1960
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1985