Complete Finance Corp. v. Commissioner
United States Tax Court
1. Petitioners Complete, Lomas, and Sandia are closely held corporations. Considering both direct and constructive ownership, a group of five persons owned over 80 percent of the stock in each corporation and over 50 percent of the stock in each corporation, taking into account each person's interest only to the extent that it was identical with respect to each corporation.
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1. Petitioners Complete, Lomas, and Sandia are closely held corporations. Considering both direct and constructive ownership, a group of five persons owned over 80 percent of the stock in each corporation and over 50 percent of the stock in each corporation, taking into account each person's interest only to the extent that it was identical with respect to each corporation. Three of those persons constructively owned stock in Complete, but owned no stock in that corporation directly. Held: Complete, Lomas, and Sandia constituted a brother-sister controlled group of corporations within the…
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined that petitioners are liable for deficiencies in their Federal income taxes as follows:
Petitioner Taxable year ended— Amount
Complete Finance Corp . Oct. 31, 1977 $4,833.77
Oct. 31, 1978 2,250.47
Lomas Warehouse, Inc . Oct. 31, 1977 14,797.37
Oct. 31, 1978 11,431.29
Sandia Auto Electric, Inc . Sept. 30, 1977 6,347.18
Sept. 30, 1978 3,400.46
The issues for decision are:(1) Whether petitioners constituted a brother-sister controlled group of corporations, as defined in section 1563(a)(2);1 and(2) Whether petitioners Lomas Warehouse, Inc., and Sandia Auto…
2Cases cited7 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Herbert S. Witte v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1975
- Rockwell International Corp. v. CommissionerUnited States Tax Court · 1981
2 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Complete Finance Corporation, Sandia Auto Electric, Inc., Lomas Warehouse, Inc., New Mexico Corporations v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1985
- Evans v. CommissionerUnited States Tax Court · 1988
- Convergent Technologies v. CommissionerUnited States Tax Court · 1995
- Complete Finance Corp. v. CommissionerUnited States Tax Court · 1983
- Hitachi Sales Corp. v. CommissionerUnited States Tax Court · 1992