West End Co. v. Commissioner
United States Tax Court
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
- West End Co. v. CommissionerUnited States Tax Court · 1955