Legal Opinion

West Coast Ice Co. v. Commissioner

United States Tax Court

Decided January 15, 1968No. Docket No. 6422-65PublishedCited by 33 opinions

Petitioner was a personal holding company during the taxable years ended May 31, 1954, 1959, 1960, and 1961. While it filed corporation income tax returns (Form 1120) which reflected some information about its personal holding company status, it did not file a personal holding company tax return (Form 1120H) for the taxable year ended May 31, 1954, or a schedule (PH) of personal holding company tax for the taxable years ended May 31, 1959, 1960, and 1961. Held: 1. Assessment…

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Petitioner was a personal holding company during the taxable years ended May 31, 1954, 1959, 1960, and 1961. While it filed corporation income tax returns (Form 1120) which reflected some information about its personal holding company status, it did not file a personal holding company tax return (Form 1120H) for the taxable year ended May 31, 1954, or a schedule (PH) of personal holding company tax for the taxable years ended May 31, 1959, 1960, and 1961. Held: 1. Assessment of personal holding company tax for the taxable year ended May 31, 1954, is not barred by sec. 275(a), I.R.C. 1939. The…

1Opinion of the Court

OPINION

Issue 1. Statute of Limitations

With respect to the taxable year ended May 31, 1954, petitioner contends that its corporation income tax return (Form 1120) contained all the information which would have been necessary if placed on a personal holding company tax return (Form 1120H) as required by section 39.508-1, Regs. 118, and therefore contained the essential information needed to determine if it was a personal holding company. Similarly, with respect to its taxable year ended May 31, 1960, petitioner contends that its Form 1120 contained all the information required by section…

2Cases cited8 opinions

  1. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  2. Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
  3. Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
  4. Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
  5. Tarbox Corp. v. CommissionerUnited States Tax Court · 1946

3 more not listed; retrieve them via the Exa API.

3Cited by33 opinions

  1. Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
  2. Durovic v. CommissionerUnited States Tax Court · 1970
  3. Joseph P. Lucia v. United States of AmericaCourt of Appeals for the Fifth Circuit · 1973
  4. Estate of Di Rezza v. CommissionerUnited States Tax Court · 1982
  5. Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975

28 more not listed; retrieve them via the Exa API.

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