PSB Holdings, Inc. v. Comm'r
United States Tax Court
P is the holding company of an affiliated group of corporations that files consolidated Federal income tax returns. The other members are P's wholly owned bank (B) and B's wholly owned investment company (IC). Both B and IC own tax-exempt obligations. Only B incurs interest expenses. IC's tax-exempt obligations were either purchased by IC or received from B before the subject years as contributions to capital.
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P is the holding company of an affiliated group of corporations that files consolidated Federal income tax returns. The other members are P's wholly owned bank (B) and B's wholly owned investment company (IC). Both B and IC own tax-exempt obligations. Only B incurs interest expenses. IC's tax-exempt obligations were either purchased by IC or received from B before the subject years as contributions to capital. R determined that B must include all of IC's tax-exempt obligations in the calculation of B's average adjusted bases of tax-exempt obligations under secs. 265(b)(2)(A) and…
1Opinion of the Court
OPINION
Laro, Judge:
This case was submitted to the Court under Rule 122 for decision without trial.1 Petitioner petitioned the Court to redetermine respondent’s determination of deficiencies of $33,622, $38,571, $41,654, and $31,868 in the 1999, 2000, 2001, and 2002 Federal income taxes, respectively, of its affiliated group. For those years, the group filed consolidated Federal corporate income tax returns. The group included petitioner, petitioner’s wholly owned subsidiary Peoples State Bank (Peoples), and Peoples’ wholly owned investment subsidiary PSB Investments, Inc. (Investments).
We…
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- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
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- Russello v. United StatesSupreme Court of the United States · 1983
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
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