Oak Hill Finance Co. v. Commissioner
United States Tax Court
Held, petitioner was a licensed personal finance company within the meaning of sec. 501(b)(6)(A), I.R.C. 1939, and sec. 542(c)(6), I.R.C. 1954, and did not constitute a personal holding company during the years involved. Held, further, that $ 4,806 paid by petitioner during each year in issue to six noteholders did not represent deductible interest.
1Opinion of the Court
Withet, Judge:
The respondent determined deficiencies in petitioner’s income tax and additions to tax as follows:
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The issues presented for our decision are (1) whether petitioner was a personal holding company within the meaning of section 501(a) of the Internal Revenue Code of 1939 and section 542(a) of the Internal Revenue Code of 1954 during its fiscal years ended June 30, 1953 through 1958; (2) in the event we hold that petitioner is a personal holding company under issue 1, whether the respondent is barred from assessing deficiencies in petitioner’s personal holding company…
2Cases cited3 opinions
- Dobkin v. CommissionerUnited States Tax Court · 1950
- United States v. South Georgia Ry. Co.Court of Appeals for the Fifth Circuit · 1939
- Jewel Tea Co. v. United StatesCourt of Appeals for the Second Circuit · 1937
3Cited by8 opinions
- Peters v. CommissionerUnited States Tax Court · 1981
- Fidelity Commercial Co. v. CommissionerUnited States Tax Court · 1970
- Bell Realty Trust v. CommissionerUnited States Tax Court · 1976
- Bell Realty Trust v. CommissionerUnited States Tax Court · 1976
- Fidelity Commercial Co. v. CommissionerUnited States Tax Court · 1970
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