Legal Opinion

West End Co. v. Commissioner

United States Tax Court

Decided January 31, 1955No. Docket No. 47182Published

1. Interest received on mortgage constituted personal holding company income because the property covered by mortgage was held by petitioner for investment purposes and not for sale in the ordinary course of its trade or business. 2. For the failure to file personal holding company income tax returns the 25 per cent penalty under section 291 (a) of the Internal Revenue Code of 1939 is approved.

1Opinion of the Court

The West End Co., Petitioner, v. Commissioner of Internal Revenue, Respondent

West End Co. v. Commissioner

Docket No. 47182

United States Tax Court

23 T.C. 815; 1955 U.S. Tax Ct. LEXIS 256;

January 31, 1955, Filed

Decision will be entered for the respondent.

1. Interest received on mortgage constituted personal holding company income because the property covered by mortgage was held by petitioner for investment purposes and not for sale in the ordinary course of its trade or business.

2. For the failure to file personal holding company income tax returns the 25 per cent penalty under section 291 (a)…

2Cases cited1 opinion

  1. West End Co. v. CommissionerUnited States Tax Court · 1955

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