Latham Park Manor, Inc. v. Commissioner
United States Tax Court
Held: Sec. 482, I.R.C. 1954, as amplified by secs. 1.482-1(d)(4) and 1.482-2(a)(1), Income Tax Regs., adopted in 1968, permits the allocation of interest income to two subsidiary corporations in respect of interest-free loans they made to their parent corporation, even though the parent corporation did not use the loan proceeds to produce income during the taxable years.
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Held: Sec. 482, I.R.C. 1954, as amplified by secs. 1.482-1(d)(4) and 1.482-2(a)(1), Income Tax Regs., adopted in 1968, permits the allocation of interest income to two subsidiary corporations in respect of interest-free loans they made to their parent corporation, even though the parent corporation did not use the loan proceeds to produce income during the taxable years. To the extent inconsistent with this opinion, Smith-Bridgman & Co. v. Commissioner, 16 T.C. 287 (1951); PPG Industries, Inc. v. Commissioner, 55 T.C. 928 (1970); Kerry Investment Co. v. Commissioner, 58 T.C. 479 (1972), affd.…
1Opinion of the Court
Featherston, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income taxes and additions to the tax pursuant to section 6651(a)(1):1
Latham Park Manor, Inc. — docket No. 2339-76
Addition to tax
Year ended June 30— Deficiency sec. 6651(a)(1)
1969 .$7,812.87 $390.64
1970 .10,046.77 2,511.69
1972 .14,232.10 3,558.03
Lind,ley Park Manor, Inc. — docket No. 2310-76
Addition to tax
Calendar year Deficiency sec. 6651(a)(1)
1969 .$21,183.07 $3,177.46
1970 .17,005.72 1,700.57
1972 .14,443.84 722.19
Due to concessions by both parties in these consolidated cases, the issues remaining for…
2Cases cited35 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
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3Cited by42 opinions
- Achiro v. CommissionerUnited States Tax Court · 1981
- Estate of Di Palma v. CommissionerUnited States Tax Court · 1978
- Fegan v. CommissionerUnited States Tax Court · 1979
- Schering Corp. v. CommissionerUnited States Tax Court · 1978
- Grace Cappuccilli v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1981
37 more not listed; retrieve them via the Exa API.