Legal Opinion

B. Forman Co. v. Commissioner

United States Tax Court

Decided May 4, 1970No. Docket Nos. 468-69, 469-69Published

In 1958, petitioners organized MidtownHoldings Corp. for the purpose of constructing and operating an enclosed mall shopping center adjacent to their department stores. They had equal ownership and control of Midtown. The shopping center opened for business in 1962. During the years in issue, Midtown paid no interest on certain loans made to it by petitioners.

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In 1958, petitioners organized MidtownHoldings Corp. for the purpose of constructing and operating an enclosed mall shopping center adjacent to their department stores. They had equal ownership and control of Midtown. The shopping center opened for business in 1962. During the years in issue, Midtown paid no interest on certain loans made to it by petitioners. In addition, petitioners made certain equal payments to Midtown ostensibly to prevent the erection of kiosks in the part of the mall adjacent to their stores. Held, that respondent may not utilize sec. 482, I.R.C. 1954, to impute…

1Opinion of the Court

B. Forman Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; McCurdy & Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

B. Forman Co. v. Commissioner

Docket Nos. 468-69, 469-69

United States Tax Court

54 T.C. 912; 1970 U.S. Tax Ct. LEXIS 149;

May 4, 1970, Filed

Decisions will be entered under Rule 50.

In 1958, petitioners organized MidtownHoldings Corp. for the purpose of constructing and operating an enclosed mall shopping center adjacent to their department stores. They had equal ownership and control of Midtown. The shopping center opened for…

2Cases cited22 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. HeiningerSupreme Court of the United States · 1943
  3. Hanover Bank v. CommissionerSupreme Court of the United States · 1962
  4. Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
  5. Dean v. CommissionerUnited States Tax Court · 1961

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