Electroline Sales Co. v. Commissioner
United States Tax Court
Petitioner received rent for use of its building by a partnership composed of three of its stockholders owning over 25 per cent of its stock. Held, the rent constituted personal holding company income, following Furniture Finance Corp., 46 B.T.A. 240. Petitioner relying on the advice of an experienced practicing accountant who audited its books and prepared tax returns for it and others did not file personal holding company returns.
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Petitioner received rent for use of its building by a partnership composed of three of its stockholders owning over 25 per cent of its stock. Held, the rent constituted personal holding company income, following Furniture Finance Corp., 46 B.T.A. 240. Petitioner relying on the advice of an experienced practicing accountant who audited its books and prepared tax returns for it and others did not file personal holding company returns. Held, the failure to file was due to reasonable cause and not to willful neglect.
1Opinion of the Court
Electroline Sales Company (formerly Electroline Manufacturing Co.) v. Commissioner.
Electroline Sales Co. v. Commissioner
Docket No. 24639.
United States Tax Court
1951 Tax Ct. Memo LEXIS 336; 10 T.C.M. (CCH) 113; T.C.M. (RIA) 51032;
January 30, 1951
Petitioner received rent for use of its building by a partnership composed of three of its stockholders owning over 25 per cent of its stock. Held, the rent constituted personal holding company income, following Furniture Finance Corp., 46 B.T.A. 240.
Petitioner relying on the advice of an experienced practicing accountant who audited its books and…
2Cases cited3 opinions
- Garrett Holding Corp. v. CommissionerUnited States Tax Court · 1947
- Minnesota Mortuaries, Inc. v. CommissionerUnited States Tax Court · 1944
- Furniture Finance Corp. v. CommissionerUnited States Board of Tax Appeals · 1942
3Cited by1 opinion
- American Valve Co. v. United StatesDistrict Court, S.D. New York · 1956