Legal Opinion

Cooper Agency v. Commissioner

United States Tax Court

Decided January 26, 1960No. Docket No. 64669Published

1. Petitioner, through its officers, orally agreed with Perpetual Building and Loan Association (an organization which they believed to be exempt from income tax under section 101(4) of the Code of 1939), and of which they were also directors, to borrow $ 600,000 at 7 per cent "interest" to build about 200 houses. At no time during petitioner's taxable years 1950 and 1951 did Perpetual advance to petitioner net amounts of more than $ 165,000 of said amount.

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1. Petitioner, through its officers, orally agreed with Perpetual Building and Loan Association (an organization which they believed to be exempt from income tax under section 101(4) of the Code of 1939), and of which they were also directors, to borrow $ 600,000 at 7 per cent "interest" to build about 200 houses. At no time during petitioner's taxable years 1950 and 1951 did Perpetual advance to petitioner net amounts of more than $ 165,000 of said amount. Each time petitioner sold a house and lot, the proceeds were turned over to Perpetual. During the years in question, petitioner paid 7…

1Opinion of the Court

Cooper Agency, Petitioner, v. Commissioner of Internal Revenue, Respondent

Cooper Agency v. Commissioner

Docket No. 64669

United States Tax Court

33 T.C. 709; 1960 U.S. Tax Ct. LEXIS 224;

January 26, 1960, Filed

Decision will be entered under Rule 50.

1. Petitioner, through its officers, orally agreed with Perpetual Building and Loan Association (an organization which they believed to be exempt from income tax under section 101(4) of the Code of 1939), and of which they were also directors, to borrow $ 600,000 at 7 per cent "interest" to build about 200 houses. At no time during petitioner's taxable…

2Cases cited12 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  4. Higgins v. SmithSupreme Court of the United States · 1940
  5. Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932

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