Complete Finance Corp. v. Commissioner
United States Tax Court
1. Petitioners Complete, Lomas, and Sandia are closely held corporations. Considering both direct and constructive ownership, a group of five persons owned over 80 percent of the stock in each corporation and over 50 percent of the stock in each corporation, taking into account each person's interest only to the extent that it was identical with respect to each corporation.
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1. Petitioners Complete, Lomas, and Sandia are closely held corporations. Considering both direct and constructive ownership, a group of five persons owned over 80 percent of the stock in each corporation and over 50 percent of the stock in each corporation, taking into account each person's interest only to the extent that it was identical with respect to each corporation. Three of those persons constructively owned stock in Complete, but owned no stock in that corporation directly. Held: Complete, Lomas, and Sandia constituted a brother-sister controlled group of corporations within the…
1Opinion of the Court
Complete Finance Corporation, Sandia Auto Electric, Inc., and Lomas Warehouse, Inc., New Mexico Corporations, Petitioners v. Commissioner of Internal Revenue, Respondent
Complete Finance Corp. v. Commissioner
Docket No. 9266-81
United States Tax Court
80 T.C. 1062; 1983 U.S. Tax Ct. LEXIS 72; 80 T.C. No. 56;
May 25, 1983, Filed
Decision will be entered for the respondent.
1. Petitioners Complete, Lomas, and Sandia are closely held corporations. Considering both direct and constructive ownership, a group of five persons owned over 80 percent of the stock in each corporation and over 50 percent of the…
2Cases cited8 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Herbert S. Witte v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1975
- Rockwell International Corp. v. CommissionerUnited States Tax Court · 1981
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