Renton Inv. Co. v. Commissioner
United States Board of Tax Appeals
Personal holding company provisions of Revenue Act of 1936, Title I A, requiring stock ownership in not more than five individuals, held applicable to petitioner by virtue of ultimate ownership by members of same family notwithstanding that stock was owned in part through intervening operating corporation and that some of the stock was pledged and its holders insolvent.
1Opinion of the Court
*287OPINION.
OppeR :
Petitioner’s liability to tas as a personal holding company under Bevenue Act of 1936, Title I A, is litigated here not on account of the character of petitioner’s income, but solely on the question whether 50 percent of petitioner’s stock was “owned directly or indirectly by or for not more than five individuals.”1
An affirmative conclusion is resisted on two grounds: That while record ownership of well over 50 percent of petitioner’s stock was ultimately and through intervening titles held in the names of not more than five individuals, considering as one those within the…
2Cases cited1 opinion
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
3Cited by7 opinions
- Miami Nat'l Bank v. CommissionerUnited States Tax Court · 1977
- Alvord v. CommissionerUnited States Tax Court · 1959
- Alvord v. CommissionerUnited States Tax Court · 1959
- Alvord v. CommissionerUnited States Tax Court · 1959
- Bro-Jeff Theatres, Inc. v. CommissionerUnited States Tax Court · 1945
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