Woodside Acres, Inc. v. Commissioner
United States Board of Tax Appeals
GROSS INCOME - PERSONAL HOLDING COMPANY - DAIRY FARM. - Gross income, for the purpose of section 351(b)(1)(a) of the Revenue Act of 1936, as amended by section 1 of the Revenue Act of 1937, in the case ofa dairy farm, is determined by deducting the cost of production from gross sales of dairy products. The cost of feed for the cows and the wages of employees who take care of and milk the cows and prepare the dairy products for market are included in the cost of production.
1Opinion of the Court
*1126OPINION.
Murdock:
The Commissioner has determined that the petitioner is a personal holding company. The petitioner, apparently conceding that it meets the definition in other respects, claims that it is not a personal holding company because more than 20 percent of its gross income was other than personal holding company income. Sec. 351 (b) (1) (A), Eevenue Act of 1936, as amended by sec. 1, Eevenue Act of 1937. Its personal holding company income amounted to $67,212.08 and the question is thus narrowed to whether the petitioner had more than one-fourth of that amount, or $16,803.03, of gross…
2Cited by12 opinions
- Sicanoff Vegetable Oil Corporation v. Commissioner of Internal Revenue, Sicanoff Tallow Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1958
- Bayou Verret Land Co. v. CommissionerUnited States Tax Court · 1969
- Guy F. Atkinson Co. v. CommissionerUnited States Tax Court · 1984
- McCulley v. KelmDistrict Court, D. Minnesota · 1953
- Hilldun Corp. v. CommissionerUnited States Tax Court · 1967
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