Estate of Whitlock v. Commissioner
United States Tax Court
For 1963 Oil Services was a controlled foreign corporation and for 1964, 1965, and 1967, it was both a controlled foreign corporation and a foreign personal holding company. For each of those years Oil Services had an increase in its earnings invested in U.S. property as defined in sec. 956. Petitioners were Oil Services' only shareholders and were its only U.S. shareholders. For 1964, 1965, and 1967, they were subject to tax under sec. 551(b) on Oil Services' income.
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For 1963 Oil Services was a controlled foreign corporation and for 1964, 1965, and 1967, it was both a controlled foreign corporation and a foreign personal holding company. For each of those years Oil Services had an increase in its earnings invested in U.S. property as defined in sec. 956. Petitioners were Oil Services' only shareholders and were its only U.S. shareholders. For 1964, 1965, and 1967, they were subject to tax under sec. 551(b) on Oil Services' income. Held: For 1964, 1965, and 1967, petitioners were not required to include in their gross income any part of Oil Services'…
1Opinion of the Court
Estate of Leonard E. Whitlock, Deceased, Georgia M. Whitlock, Executrix, and Georgia M. Whitlock, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Whitlock v. Commissioner
Docket No. 386-70
United States Tax Court
59 T.C. 490; 1972 U.S. Tax Ct. LEXIS 2; 59 T.C. No. 48;
December 29, 1972, Filed
Decision will be entered under Rule 50.
For 1963 Oil Services was a controlled foreign corporation and for 1964, 1965, and 1967, it was both a controlled foreign corporation and a foreign personal holding company. For each of those years Oil Services had an increase in its earnings…
Also in this document: Dissent.
2Cases cited49 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Helvering v. CliffordSupreme Court of the United States · 1940
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
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