Allen Machinery Corp. v. Commissioner
United States Tax Court
Income was received by petitioner during the years in issue pursuant to two service contracts with another corporation. Held, that the second of the two contracts involved designated the president of petitioner personally to perform services, and therefore the income received thereunder during the taxable year ended January 31, 1954, was personal holding company income under section 502 (e), I. R. C. 1939. General Management Corporation, 46 B. T. A. 738, followed.
1Opinion of the Court
Allen Machinery Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Allen Machinery Corp. v. Commissioner
Docket No. 62163
United States Tax Court
31 T.C. 441; 1958 U.S. Tax Ct. LEXIS 23;
November 28, 1958, Filed
Decision will be entered under Rule 50.
Income was received by petitioner during the years in issue pursuant to two service contracts with another corporation. Held, that the second of the two contracts involved designated the president of petitioner personally to perform services, and therefore the income received thereunder during the taxable year ended January 31,…
2Cases cited2 opinions
- General Management Corp. v. COM'R OF INT. REVENUECourt of Appeals for the Seventh Circuit · 1943
- Allen Machinery Corp. v. CommissionerUnited States Tax Court · 1958