Investors Ins. Agency, Inc. v. Commissioner
United States Tax Court
Certain individuals initially guaranteed a minimum rate of return on petitioner's investment in a joint venture. Subsequently, the individuals paid the interest accrued to the date of payment and agreed to thereafter make periodic payments as the interest accrued and to pay the principal amount at a date certain, if not previously paid to petitioner by the joint venture. Held, the accrued payment is interest for personal holding company income purposes.
1Opinion of the Court
Investors Insurance Agency, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Investors Ins. Agency, Inc. v. Commissioner
Docket No. 4457-78
United States Tax Court
72 T.C. 1027; 1979 U.S. Tax Ct. LEXIS 65;
September 10, 1979, Filed
Decision will be entered for the respondent.
Certain individuals initially guaranteed a minimum rate of return on petitioner's investment in a joint venture. Subsequently, the individuals paid the interest accrued to the date of payment and agreed to thereafter make periodic payments as the interest accrued and to pay the principal amount at a date…
2Cases cited7 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Rushing v. CommissionerUnited States Tax Court · 1972
- Investors Ins. Agency, Inc. v. CommissionerUnited States Tax Court · 1979
- Commissioner of Internal Revenue v. BanfieldCourt of Appeals for the Ninth Circuit · 1941
2 more not listed; retrieve them via the Exa API.