Fidelity Commercial Co. v. Commissioner
United States Tax Court
Petitioner sought to exclude itself from classification as a personal holding company on the ground that it was a lending and finance company satisfying all the requirements of sec. 542(c)(6). In 1965 one of its shareholders, who owned more than 10 percent in value of its outstanding stock, withdrew from petitioner amounts in excess of $ 5,000. Held, the withdrawals were in fact loans within the meaning of sec. 542(c)(6)(D) and, therefore, petitioner was a personal holding…
Read the full summary
Petitioner sought to exclude itself from classification as a personal holding company on the ground that it was a lending and finance company satisfying all the requirements of sec. 542(c)(6). In 1965 one of its shareholders, who owned more than 10 percent in value of its outstanding stock, withdrew from petitioner amounts in excess of $ 5,000. Held, the withdrawals were in fact loans within the meaning of sec. 542(c)(6)(D) and, therefore, petitioner was a personal holding company during 1965.
1Opinion of the Court
Fidelity Commercial Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Fidelity Commercial Co. v. Commissioner
Docket No. 4813-68
United States Tax Court
55 T.C. 483; 1970 U.S. Tax Ct. LEXIS 12;
December 14, 1970, Filed
Decision will be entered for the respondent.
Petitioner sought to exclude itself from classification as a personal holding company on the ground that it was a lending and finance company satisfying all the requirements of sec. 542(c)(6). In 1965 one of its shareholders, who owned more than 10 percent in value of its outstanding stock, withdrew from petitioner amounts…
2Cases cited15 opinions
- Estate of E. W. Chism, Deceased, Clara Chism, and Clara Chism v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Paul W. Berthold and Dorothy Berthold v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1968
- Rose v. CommissionerUnited States Tax Court · 1970
- Hans Zimmerman and Clara Zimmerman, Apellants v. United States of America and District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Rude v. CommissionerUnited States Tax Court · 1967
10 more not listed; retrieve them via the Exa API.