Ballentine Motor Co. v. Commissioner
United States Tax Court
The president and controlling stockholder of various controlled corporate automobile dealers contracted with a finance company to receive personally rebates from finance paper on installment sales by the dealers. These rebates were in addition to those granted under the contracts with the dealers and thus in excess of those customarily granted by the finance company. One dealership had a large operating deficit.
Read the full summary
The president and controlling stockholder of various controlled corporate automobile dealers contracted with a finance company to receive personally rebates from finance paper on installment sales by the dealers. These rebates were in addition to those granted under the contracts with the dealers and thus in excess of those customarily granted by the finance company. One dealership had a large operating deficit. In 1954 it received loans from a related controlled management corporation to purchase at cost inventories from two profitable related corporations. After 1954 these inventories,…
1Opinion of the Court
FORRESTER, Judge:
Respondent has determined the following deficiencies in income tax of petitioners:
[[Image here]]
Certain adjustments have been agreed to by all petitioners. The issues remaining for our consideration are (1) whether certain payments made by Commercial Credit Corporation to C. M. Ballentine constitute income to petitioners, and (2) whether certain income reported by another corporation should have been reported by petitioners in Docket Nos. 83228 and 83229.
FINDINGS OF FACT.
Some of the facts have been stipulated and are so found.
Ballentine Motor Co., Inc. (hereinafter referred…
2Cases cited14 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- GUR Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1941
- United Dressed Beef Co. v. CommissionerUnited States Tax Court · 1955
9 more not listed; retrieve them via the Exa API.
3Cited by74 opinions
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Foster v. Comm'rUnited States Tax Court · 1983
- Ach v. CommissionerUnited States Tax Court · 1964
- Riss v. CommissionerUnited States Tax Court · 1971
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
69 more not listed; retrieve them via the Exa API.