Western Transmission Corp. v. Commissioner
United States Tax Court
1. During the taxable years petitioner's income was derived primarily from rentals on its property leased to a partnership composed principally of petitioner's five shareholders. Held, petitioner is a personal holding company as defined in sections 500- 502 of the Internal Revenue Code. 2. Petitioner failed to file personal holding company returns for each of the taxable years relying upon its tax advisers.
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1. During the taxable years petitioner's income was derived primarily from rentals on its property leased to a partnership composed principally of petitioner's five shareholders. Held, petitioner is a personal holding company as defined in sections 500- 502 of the Internal Revenue Code. 2. Petitioner failed to file personal holding company returns for each of the taxable years relying upon its tax advisers. Held, petitioner's failure to file the required returns was due to reasonable cause and was not due to neglect, and petitioner is not subject to a penalty therefor.
1Opinion of the Court
Western Transmission Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Western Transmission Corp. v. Commissioner
Docket No. 29490
United States Tax Court
18 T.C. 818; 1952 U.S. Tax Ct. LEXIS 129;
July 30, 1952, Promulgated
Decision will be entered accordingly.
1. During the taxable years petitioner's income was derived primarily from rentals on its property leased to a partnership composed principally of petitioner's five shareholders. Held, petitioner is a personal holding company as defined in sections 500- 502 of the Internal Revenue Code.
2. Petitioner failed to file…
2Cases cited15 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Weiss v. WeinerSupreme Court of the United States · 1929
- Commissioner of Internal Revenue v. WhitneyCourt of Appeals for the Second Circuit · 1948
- Randolph Products Co. v. ManningCourt of Appeals for the Third Circuit · 1949
- Jennings v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1940
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