Joyce v. Commissioner
United States Tax Court
1. Held, that more than 20 percent of the 1959 gross receipts of Farmingdale, a corporation wholly owned by the petitioner, was derived from personal holding company income and that, pursuant to the provisions of section 1372(e)(5) of the Internal Revenue Code of 1954, Farmingdale's election not to be subject to the taxes imposed by chapter 1 of the Code was terminated, and that accordingly the petitioner is not entitled to deduct Farmingdale's net operating loss for the…
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1. Held, that more than 20 percent of the 1959 gross receipts of Farmingdale, a corporation wholly owned by the petitioner, was derived from personal holding company income and that, pursuant to the provisions of section 1372(e)(5) of the Internal Revenue Code of 1954, Farmingdale's election not to be subject to the taxes imposed by chapter 1 of the Code was terminated, and that accordingly the petitioner is not entitled to deduct Farmingdale's net operating loss for the taxable year 1959. 2. Held, further, that the gains on sales of certain stock which the petitioner deposited with a bank as…
1Opinion of the Court
Temple N. Joyce and Louisa D. Joyce, Petitioners, v. Commissioner of Internal Revenue, Respondent
Joyce v. Commissioner
Docket No. 93342
United States Tax Court
42 T.C. 628; 1964 U.S. Tax Ct. LEXIS 85;
June 23, 1964, Filed
Decision will be entered under Rule 50.
1. Held, that more than 20 percent of the 1959 gross receipts of Farmingdale, a corporation wholly owned by the petitioner, was derived from personal holding company income and that, pursuant to the provisions of section 1372(e)(5) of the Internal Revenue Code of 1954, Farmingdale's election not to be subject to the taxes imposed by chapter…
2Cases cited16 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
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- United States v. PhellisSupreme Court of the United States · 1921
- Weiss v. StearnSupreme Court of the United States · 1924
- United States v. New YorkSupreme Court of the United States · 1942
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