Your Host, Inc. v. Commissioner
United States Tax Court
1. Your Host, Inc., was formed in 1947 by Wesson and Durrenberger to operate four Your Host Restaurants. Between 1948 and 1956 10 more corporations were formed to operate Your Host Restaurants. In 1969 there were 40 Your Host Restaurants of which Your Host operated 15 with each of the other restaurant corporations operating four or fewer locations.
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1. Your Host, Inc., was formed in 1947 by Wesson and Durrenberger to operate four Your Host Restaurants. Between 1948 and 1956 10 more corporations were formed to operate Your Host Restaurants. In 1969 there were 40 Your Host Restaurants of which Your Host operated 15 with each of the other restaurant corporations operating four or fewer locations. In addition to Your Host and the 10 restaurant corporations, Wesson and Durrenberger formed a commissary corporation in 1947, a real estate holding corporation in 1951, and a bakery corporation in 1955. Following Wesson's death Durrenberger formed…
1Opinion of the Court
IrwiN, Judge:
Respondent determined the following deficiencies in the corporate income taxes of petitioners:
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Respondent bas conceded that petitioners Yonr Host, Inc., and Sher-Del Foods, Inc., are not subject to the acoumulated-earnings tax imposed 'by section 5312 for the years in question. After other concessions the following issues remain for decision:(1) Whether respondent was arbitrary in allocating under section 482 all of the income and deductions of the 10 corporations operating restaurants and the vending machine corporation to Your Host, Inc.; and(2) In…
2Cases cited16 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
- Ballentine Motor Co. v. CommissionerUnited States Tax Court · 1962
- Bobsee Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1969
11 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Hospital Corp. of America v. CommissionerUnited States Tax Court · 1983
- Your Host, Inc. v. Commissioner of Internal Revenue, Chef Foods, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1973
- Merck & Co. v. United StatesUnited States Court of Claims · 1991
- Peck v. CommissionerUnited States Tax Court · 1982
- Gettler v. CommissionerUnited States Tax Court · 1975
12 more not listed; retrieve them via the Exa API.