Furniture Finance Corp. v. Commissioner
United States Board of Tax Appeals
1. A corporation the shares of which are owned by two individuals and the income of which is derived from rent of its building to a partnership composed of the two shareholders, held a personal holding company, the income being personal holding company income. 2. The failure to file a personal holding company surtax return held without reasonable cause and to support penalty.
1Opinion of the Court
OPINION.
Sternhagen :
The Commissioner determined a deficiency for 1937 of $3,162.80 in personal holding company surtax, and a penalty of $790.70 for failure to file a personal holding company surtax return. *241The facts are stipulated and the stipulation is hereby adopted as the findings of fact.
The petitioner was organized on or about February 19, 1936, under the laws of Oregon, and its return was filed in Portland, Oregon. Its shares were owned by David Light and Harry W. Zavin. Its income for the taxable year was derived from rent of a building which it owned and leased to a copartnership of…
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