Cayuga Service, Inc. v. Commissioner
United States Tax Court
Interest-free advances were made by petitioner, a corporation, to VLA, VSD and YS corporations. Held, (1) petitioner and the three corporations were controlled corporations within the purview of section 482, both at the time of the advances and for the years in issue, 1966 and 1967; (2) the advances determined to be nonarm's-length loans not investments; and (3) following B. Forman Company v. Commissioner, 453 F.2d 1144 (C.A. 2, 1972), certiorari denied 407 U.S. 934 (1972)…
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Interest-free advances were made by petitioner, a corporation, to VLA, VSD and YS corporations. Held, (1) petitioner and the three corporations were controlled corporations within the purview of section 482, both at the time of the advances and for the years in issue, 1966 and 1967; (2) the advances determined to be nonarm's-length loans not investments; and (3) following B. Forman Company v. Commissioner, 453 F.2d 1144 (C.A. 2, 1972), certiorari denied 407 U.S. 934 (1972) (Golsen rule applied), respondent had the power under section 482 to allocate gross income to petitioner measured by five…
1Opinion of the Court
CAYUGA SERVICE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cayuga Service, Inc. v. Commissioner
Docket No. 6442-70.
United States Tax Court
T.C. Memo 1975-4; 1975 Tax Ct. Memo LEXIS 368; 34 T.C.M. (CCH) 18; T.C.M. (RIA) 750004;
January 13, 1975, Filed.
Interest-free advances were made by petitioner, a corporation, to VLA, VSD and YS corporations. Held, (1) petitioner and the three corporations were controlled corporations within the purview of section 482, both at the time of the advances and for the years in issue, 1966 and 1967; (2) the advances determined to be…
2Cases cited12 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Dixon v. United StatesSupreme Court of the United States · 1965
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Schmitz v. CommissionerUnited States Tax Court · 1968
7 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- W. L. Gore & Assocs. v. CommissionerUnited States Tax Court · 1995