Marprowear Profit-Sharing Trust v. Commissioner
United States Tax Court
Petitioner is a profit-sharing trust qualified under sec. 401, I.R.C. 1954. It purchased a shopping center with a purchase-money mortgage obtained from a third party plus certain sums transferred to it from the corporation founding the trust.
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Petitioner is a profit-sharing trust qualified under sec. 401, I.R.C. 1954. It purchased a shopping center with a purchase-money mortgage obtained from a third party plus certain sums transferred to it from the corporation founding the trust. Held, the transfers from the corporation to the trust to purchase the shopping center are "acquisition indebtedness" within the meaning of sec. 514. Held, further, the trust's unrelated business taxable income is taxable at trust and not corporate rates. Held, further, sec. 6651(a) addition to tax not applicable.
1Opinion of the Court
Marprowear Profit-Sharing Trust c/o Harry Riback, Martin Riback, Joseph Weinberg, and Charles Riback, Trustees, Petitioner v. Commissioner of Internal Revenue, Respondent
Marprowear Profit-Sharing Trust v. Commissioner
Docket No. 1363-78
United States Tax Court
74 T.C. 1086; 1980 U.S. Tax Ct. LEXIS 76; 74 T.C. No. 80;
August 22, 1980, Filed
Decision will be entered for the respondent.
Petitioner is a profit-sharing trust qualified under sec. 401, I.R.C. 1954. It purchased a shopping center with a purchase-money mortgage obtained from a third party plus certain sums transferred to it from the…
2Cases cited7 opinions
- Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- West Coast Ice Co. v. CommissionerUnited States Tax Court · 1968
- Ferrando v. United StatesCourt of Appeals for the Ninth Circuit · 1957
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