Steuben Sec. Corp. v. Commissioner
United States Tax Court
The word "beneficiaries" appearing in the description of constructive ownership of stock in a personal holding company means those persons who have present interests in a trust holding the shares and excludes those who have a remainder or other remote interest, whether vested or contingent.
1Opinion of the Court
OPINION.
Steenhagen, Judge:
For the taxable years 1987 and 1938, the Commissioner has determined that the petitioner was a personal holding company as defined in the revenue acts of 1937, sections 352 and 354, and .1938, sections 402 and 404. The definition has now been carried into the Internal Revenue Code, chapter 2, subchapter A. Petitioner says that sections 503 (a) (1) and (2) 1 are inapplicable because more than 50 percent in value of its outstanding shares was not owned either actually or constructively by or for five or less individuals. It says that the statutory meaning of…
2Cases cited2 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Helvering v. HallockSupreme Court of the United States · 1940
3Cited by5 opinions
- Mitchell v. CommissionerUnited States Tax Court · 1960
- Robert L. Phinney v. Tuboscope CompanyCourt of Appeals for the Fifth Circuit · 1959
- Mitchell v. CommissionerUnited States Tax Court · 1960
- Robert L. Phinney v. Tuboscope CompanyCourt of Appeals for the Fifth Circuit · 1959
- Steuben Sec. Corp. v. CommissionerUnited States Tax Court · 1943