Western Credit Co. v. Commissioner
United States Tax Court
Held, "contract charges" made by a nonregulated small loan company to help cover the high cost of investigating credit, the increased risk involved, etc., in such business, constitute interest and personal holding company income.
1Opinion of the Court
Drennen, Judge:
Respondent determined that there is due from petitioner deficiencies in personal holding company surtax and in income tax for the periods and in the amounts following:
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The only issue for decision is whether petitioner is liable for tax as a personal holding company.
findings of fact.
Some of the facts have been stipulated and are found accordingly.
Petitioner is a corporation, incorporated in 1948 under the laws of Montana, with its principal place of business in Great Falls, Montana. It filed Federal income tax returns for the calendar years 1949 through 1954, for…
2Cases cited9 opinions
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Girard Inv. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1941
- R. Simpson & Co. v. CommissionerSupreme Court of the United States · 1944
- Noteman v. WelchCourt of Appeals for the First Circuit · 1939
- General American Life Ins. Co. v. CommissionerUnited States Tax Court · 1956
4 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Gunderson Bros. Engineering Corp. v. CommissionerUnited States Tax Court · 1964
- Hyde v. Comm'rUnited States Tax Court · 1975
- MacEy Jewelry Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Capital One Fin. Corp. v. Comm'rUnited States Tax Court · 2009
- North American Loan & Thrift Co. v. CommissionerUnited States Tax Court · 1962
12 more not listed; retrieve them via the Exa API.