Legal Opinion
Parkside, Inc. And Beaconcrest, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided December 2, 1977No. 75-2893PublishedCited by 22 opinions
1Opinion of the Court
CHOY, Circuit Judge:
The Commissioner of Internal Revenue (Commissioner) issued deficiency notices to taxpayer-appellants Parkside, Inc. (Park-side) and Beaconcrest, Inc. (Beaconcrest) upon determining that income reported as interest for certain taxable years brought the two corporations within the rigorous provisions of the personal holding company tax (PHCT), Int.Rev.Code of 1954, §§ 541-47,1 and the Tax Court agreed. We reverse.
The basic facts in this case are undisputed. Parkside and Beaconcrest are Washington state corporations, the stock of which is owned in equal shares by three…
2Cases cited42 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Malat v. RiddellSupreme Court of the United States · 1966
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
37 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Byram v. United StatesCourt of Appeals for the Fifth Circuit · 1983
- Cottle v. CommissionerUnited States Tax Court · 1987
- McManus v. CommissionerCourt of Appeals for the Ninth Circuit · 1978
- Redwood Empire Savings & Loan Association v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
17 more not listed; retrieve them via the Exa API.