Legal Opinion
Silverman & Sons Realty Trust v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided May 15, 1980No. 80-1014PublishedCited by 3 opinions
1Opinion of the Court
LEVIN H. CAMPBELL, Circuit Judge.
The Commissioner of Internal Revenue appeals from a decision of the United States Tax Court holding that taxpayer— Silverman & Sons Realty Trust (“the Trust”) — was not liable for a tax on personal holding company income under Section 541 of the Internal Revenue Code of 1954, 26 U.S.C. § 541. The issue presented is whether rental income received by the Trust from a corporation whose principal shareholders were also the sole shareholders of the Trust constituted personal holding company income within the terms of 26 U.S.C. § 543(a)(6). The resolution of this…
2Cases cited8 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Fulman v. United StatesSupreme Court of the United States · 1978
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- Minnesota Mortuaries, Inc. v. CommissionerUnited States Tax Court · 1944
- 320 E. 47th Street Corp. v. CommissionerUnited States Tax Court · 1956
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3Cited by3 opinions
- Magnolia Surf, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1980
- Mourad v. Commissioner of IRSCourt of Appeals for the First Circuit · 2004
- Allied Industrial Cartage Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981