Sunshine Dep't Stores v. Commissioner
United States Tax Court
Petitioner was one of a group of related entities, including three corporations, a partnership and an estate. The estate controlled the voting stock of petitioner and another of the corporations and a substantial bloc of stock of the third corporation. A majority of the estate's fiduciaries were also its principal beneficiaries and owned or controlled substantial interests in the other entities.
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Petitioner was one of a group of related entities, including three corporations, a partnership and an estate. The estate controlled the voting stock of petitioner and another of the corporations and a substantial bloc of stock of the third corporation. A majority of the estate's fiduciaries were also its principal beneficiaries and owned or controlled substantial interests in the other entities. Over the course of a number of years, petitioner made substantial interest-free loans to each of the other entities. The respondent allocated interest income on the loans to petitioner under sec. 482,…
1Opinion of the Court
SUNSHINE DEPARTMENT STORES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sunshine Dep't Stores v. Commissioner
Docket No. 1161-78.
United States Tax Court
T.C. Memo 1981-586; 1981 Tax Ct. Memo LEXIS 159; 42 T.C.M. (CCH) 1379; T.C.M. (RIA) 81586;
October 7, 1981.
Petitioner was one of a group of related entities, including three corporations, a partnership and an estate. The estate controlled the voting stock of petitioner and another of the corporations and a substantial bloc of stock of the third corporation. A majority of the estate's fiduciaries were also its principal…
2Cases cited18 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Ach v. CommissionerUnited States Tax Court · 1964
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