Kenyatta Corp. v. Commissioner
United States Tax Court
Petitioner was organized in 1973 to provide personal services such as radio and television appearances, sportscasting, college campus lectures, newspaper columns, and the like.
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Petitioner was organized in 1973 to provide personal services such as radio and television appearances, sportscasting, college campus lectures, newspaper columns, and the like. Respondent determined that petitioner is liable under sec. 541, I.R.C. 1954, for personal holding company tax for its fiscal year ended Jan. 31, 1978. Held, the burden of proof rests with petitioner regardless of whether the Commissioner's agents examined all of petitioner's personal service contracts before the notice of deficiency was issued. Held, further, the stock ownership test prescribed by sec. 542(a)(2),…
1Opinion of the Court
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $24,943 in petitioner’s personal holding company tax for its fiscal year ended January 31, 1978. The only issue to be decided is whether, during that year, petitioner was a personal holding company within the meaning of section 542(a).1
FINDINGS OF FACT
Petitioner Kenyatta Corp. was a Washington State corporation with its principal office located in Seattle, Washington, at the time the petition was filed. Petitioner timely filed its corporate Federal income tax return for its fiscal year 1978 with the Internal Revenue…
2Cases cited15 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Holland v. United StatesSupreme Court of the United States · 1955
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Johnny Weimerskirch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- Weimerskirch v. CommissionerUnited States Tax Court · 1977
10 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Deskins v. CommissionerUnited States Tax Court · 1986
- Markman v. CommissionerUnited States Tax Court · 1987
- Kenyatta Corp. v. CommissionerCourt of Appeals for the Ninth Circuit · 1987
- Calypso Music, Inc. v. CommissionerUnited States Tax Court · 2000
- Deskins v. CommissionerUnited States Tax Court · 1986
5 more not listed; retrieve them via the Exa API.