Bartell Hotel Co. v. Commissioner
United States Tax Court
Held, that the income derived from the operation of a hotel business by another corporation, in the hotel building owned by petitioner, was not attributable to petitioner.
1Opinion of the Court
Mtjlroney, Judge:
The respondent determined deficiencies in income tax of petitioner for the years 1951, 1952, and 1953 in the respective amounts of $30,547.03, $13,502.60, and $5,741.79, together with additions to the tax under section 291(a) of the Internal Revenue Code of 1939 for the taxable years 1952 and 1953 in the respective amounts of $4,616.32 and $1,435.45.
The principal issue involved is whether income derived from the operation of a hotel during the years 1951 to 1953, inclusive, was taxable to petitioner, the owner of the hotel. Because of our decision on this issue, other issues,…
2Cases cited5 opinions
- Nelson v. CommissionerUnited States Tax Court · 1946
- 2 Lexington Ave. Corp. v. CommissionerUnited States Tax Court · 1956
- Whitfield v. CommissionerUnited States Tax Court · 1950
- L. T. Campbell, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1947
- Whitfield's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
3Cited by13 opinions
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- Ourisman v. CommissionerUnited States Tax Court · 1984
- K-C Land Co. v. CommissionerUnited States Tax Court · 1960
- State-Adams Corp. v. CommissionerUnited States Tax Court · 1959
- Timanus v. CommissionerUnited States Tax Court · 1959
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