Legal Opinion
Investors Insurance Agency, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 26, 1982No. 79-7590PublishedCited by 12 opinions
1Opinion of the Court
EUGENE A. WRIGHT, Circuit Judge:
The Commissioner of Internal Revenue (Commissioner) assessed Investors Insurance Agency, Inc. (Taxpayer) with a deficiency when it determined that $130,000 interest received by taxpayer in 1974 triggered the provisions of the personal holding company tax. 26 U.S.C. § 541. The Tax Court affirmed the deficiency assessment, rejecting taxpayer’s argument that the $130,000 was not interest. Investors Insurance Agency, Inc. v. Commissioner, 72 T.C. 1027 (1979). We affirm.
In 1963, taxpayer entered into a joint venture with Sherwood Development Co. (Sherwood) to…
2Cases cited8 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner of Internal Revenue v. Philadelphia Transp. Co.Court of Appeals for the Third Circuit · 1949
- Lloyd W. Golder, Jr. And Esther Golder v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1979
- In the Matter of Charles A. Steen, Debtor. Dick Dimond, Trustee v. United StatesCourt of Appeals for the Ninth Circuit · 1975
- Dunlap v. CommissionerUnited States Tax Court · 1980
3 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Smith v. CommissionerUnited States Tax Court · 1985
- Michiko Noguchi v. Commissioner of Internal Revenue Service, Robert R. Midkiff and Evanita S. Midkiff v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Hunt v. CommissionerUnited States Tax Court · 1990
- Krueger Co. v. CommissionerUnited States Tax Court · 1982
- TAIYO HAWAII CO. v. COMMISSIONERUnited States Tax Court · 1997
7 more not listed; retrieve them via the Exa API.