Legal Opinion

Family Group, Inc. v. Commissioner

United States Tax Court

Decided February 12, 1973No. Docket No. 4673-70Published

P acquired eight junior mortgages and underlying notes shortly after it was incorporated in November 1964. The junior mortgages required petitioner to discharge certain senior mortgages and liens out of collections.

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P acquired eight junior mortgages and underlying notes shortly after it was incorporated in November 1964. The junior mortgages required petitioner to discharge certain senior mortgages and liens out of collections. Held, the payments which petitioner made or caused to be made to the senior mortgagees and lienholders during 1967 were motivated primarily by petitioner's liability as holder of the junior mortgages rather than petitioner's fear of foreclosure, and such payments are hence nondeductible capital expenditures. Held, further, petitioner was subject to the personal holding company tax…

1Opinion of the Court

Family Group, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Family Group, Inc. v. Commissioner

Docket No. 4673-70

United States Tax Court

59 T.C. 660; 1973 U.S. Tax Ct. LEXIS 174;

February 12, 1973, Filed

Decision will be entered for the respondent.

P acquired eight junior mortgages and underlying notes shortly after it was incorporated in November 1964. The junior mortgages required petitioner to discharge certain senior mortgages and liens out of collections. Held, the payments which petitioner made or caused to be made to the senior mortgagees and lienholders during 1967 were…

2Cases cited1 opinion

  1. Family Group, Inc. v. CommissionerUnited States Tax Court · 1973

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