Eller v. Commissioner
United States Tax Court
One of the corporate petitioners derived income from the operation of a commercial shopping center and a mobile home park. Held, this income constitutes personal holding company income (rents) within the meaning of sec. 543(a)(2), I.R.C. 1954. Webster Corp. v. Commissioner, 25 T.C. 55 (1955), affd. per curiam 240 F.2d 164 (2d Cir. 1957), distinguished.
Read the full summary
One of the corporate petitioners derived income from the operation of a commercial shopping center and a mobile home park. Held, this income constitutes personal holding company income (rents) within the meaning of sec. 543(a)(2), I.R.C. 1954. Webster Corp. v. Commissioner, 25 T.C. 55 (1955), affd. per curiam 240 F.2d 164 (2d Cir. 1957), distinguished. A related partnership sold real estate situated on which was a single-family dwelling which the individual petitioners continued to occupy rent free for a 2-year period following the sale. Held, petitioners' possessory interest was based on a…
1Opinion of the Court
Walt E. Eller and Dorothy M. Eller, Petitioners v. Commissioner of Internal Revenue, Respondent; Walt Eller Trailer Sales of Modesto, Inc., and Walt Eller Trailer Sales of Merced, Inc., Petitioners v. Commissioner of Internal Revenue, Respondent
Eller v. Commissioner
Docket Nos. 3249-80, 3250-80
United States Tax Court
77 T.C. 934; 1981 U.S. Tax Ct. LEXIS 33;
October 29, 1981, Filed
Decisions will be entered under Rule 155.
One of the corporate petitioners derived income from the operation of a commercial shopping center and a mobile home park. Held, this income constitutes personal holding company…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Interstate Circuit, Inc. v. United StatesSupreme Court of the United States · 1939
- Willcutts v. BunnSupreme Court of the United States · 1931
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
9 more not listed; retrieve them via the Exa API.