Perpetual Bldg. & Loan Asso. v. Commissioner
United States Tax Court
1. Petitioner, incorporated as a building and loan association under the laws of the State of South Carolina, was advised of exemption from Federal income taxes under section 101(4) of the 1939 Code by revenue ruling letter issued in 1946. Thereafter, for each of the years 1946 to 1951, inclusive, petitioner filed information returns (Form 990) with the collector of internal revenue.
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1. Petitioner, incorporated as a building and loan association under the laws of the State of South Carolina, was advised of exemption from Federal income taxes under section 101(4) of the 1939 Code by revenue ruling letter issued in 1946. Thereafter, for each of the years 1946 to 1951, inclusive, petitioner filed information returns (Form 990) with the collector of internal revenue. During said years petitioner acquired considerable real estate, much of which came from members of the Cooper family (who dominated and for practical purposes controlled petitioner), or from corporations which…
1Opinion of the Court
Fishee, Judge:
Respondent determined deficiencies in income tax, declared value excess-profits tax, excess profits tax, and additions to the tax under section 291(a), Code of 1939, as follows:
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The issues presented are:
1. Whether the petitioner was exempt from taxation under the provisions of section 101(4) of the Code of 1939 during the years 1945 to 1951, inclusive; (2) whether petitioner is liable for additions to the tax under section 291(a), supra, for said years; (3) whether the statute of limitations has expired for assessment and collection of the deficiencies due from…
2Cases cited23 opinions
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- Hopkins Federal Savings & Loan Ass'n v. ClearySupreme Court of the United States · 1935
- Robert A. Henningsen, and Cross and R.A. And Margaret Henningsen v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
- United States v. Cambridge Loan & Building Co.Supreme Court of the United States · 1928
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- Texas Learning Technology Group v. CommissionerUnited States Tax Court · 1991
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