Lake Textile Co. v. Commissioner
United States Tax Court
G operated the soft goods departments in several discount department stores and formed a separate corporation for the operation in each store. He and his wife held all the outstanding stock in such corporations. The evidence indicates that the separate corporations were formed for business reasons and that tax consequences were not considered.
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G operated the soft goods departments in several discount department stores and formed a separate corporation for the operation in each store. He and his wife held all the outstanding stock in such corporations. The evidence indicates that the separate corporations were formed for business reasons and that tax consequences were not considered. G made loans to one of the petitioners with no obligation to pay interest and no due date, but after several years, the debtor made payments to G which were deducted as interest. Held: (1) The evidence as to the reasons for the formation of the separate…
1Opinion of the Court
Lake Textile Co., Inc., et al. 1 v. Commissioner.
Lake Textile Co. v. Commissioner
Docket Nos. 1233-66, 1252-66 - 1255-66, 1272-66, 6723-66 - 6726-66, 6735-66, 6745-66.
United States Tax Court
T.C. Memo 1969-44; 1969 Tax Ct. Memo LEXIS 252; 28 T.C.M. (CCH) 246; T.C.M. (RIA) 69044;
March 5, 1969, Filed
G operated the soft goods departments in several discount department stores and formed a separate corporation for the operation in each store. He and his wife held all the outstanding stock in such corporations. The evidence indicates that the separate corporations were formed for business reasons and…
2Cases cited9 opinions
- D. Loveman & Son Export Corp. v. CommissionerUnited States Tax Court · 1960
- James Realty Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Hawaiian Trust Company Limited v. United StatesCourt of Appeals for the Ninth Circuit · 1961
- Howell Turpentine Co. v. Commissioner of Internal Rev.Court of Appeals for the Fifth Circuit · 1947
- Clarksdale Rubber Co. v. CommissionerUnited States Tax Court · 1965
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3Cited by1 opinion
- Thrifty Supply of Spokane, Inc. v. CommissionerUnited States Tax Court · 1976