Southern Ford Tractor Corp. v. Commissioner
United States Tax Court
The corporate petitioner sold its real estate to Farm Industries, a corporation whose stock was owned personally by children, or held in trust for children, of the stockholders of the corporate petitioner. This property, and other property, was leased from Farm Industries on a percentage of sales rental basis. Southern Ford deducted such rental as ordinary and necessary business expenses.
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The corporate petitioner sold its real estate to Farm Industries, a corporation whose stock was owned personally by children, or held in trust for children, of the stockholders of the corporate petitioner. This property, and other property, was leased from Farm Industries on a percentage of sales rental basis. Southern Ford deducted such rental as ordinary and necessary business expenses. Held, on the basis of the record before us, the sales price of the corporate petitioner's property was not less than its fair market value. Held, further, the rental accrued by Southern Ford was required to…
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies in income taxes of the petitioners as follows:
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The 'issues raised by the pleadings in these consolidated cases are (1) whether thé iAdi vidual petitioners realized distributions in the nature of dividends in 1959 or 1953 from the corporate petitioner; (2) whether the rentals accrued by the corporate petitioner on the property rented from Farm Industries, Inc., were in part, or in total, ordinary and nehéssafy business expenses in the years before us; (3) whether the expenditure in fiscal 1951 by the corporate petitioner for…
2Cases cited5 opinions
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Place v. CommissionerUnited States Tax Court · 1951
- JM Perry & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1941
- Utter-Mckinley Mortuaries, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Timberlake v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1942
3Cited by49 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Richard R. Riss, Sr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1973
- Blanco v. CommissionerUnited States Tax Court · 1971
- American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
- United States v. W. J. Wehrli and Helen B. WehrliCourt of Appeals for the Tenth Circuit · 1968
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