Lewisville Inv. Co. v. Commissioner
United States Tax Court
1. Three corporations (A, B, and C) were organized to carry on a potato-processing business. A owned all the land and buildings and provided management services, including supervisory and clerical personnel for the other two corporations. B owned the processing equipment, handled the manufacturing and employed the nonsupervisory personnel.
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1. Three corporations (A, B, and C) were organized to carry on a potato-processing business. A owned all the land and buildings and provided management services, including supervisory and clerical personnel for the other two corporations. B owned the processing equipment, handled the manufacturing and employed the nonsupervisory personnel. C, originally designed to sell the finished products, never performed this function; it carried no inventory of goods and directly employed no one. All sales personnel were employed by A. Respondent disallowed the surtax exemption claimed by A and C. Held,…
1Opinion of the Court
Featherston, Judge:
Respondent determined income tax deficiencies as follows:
Docket No. Taxable year ending Aug. Si Amount
6393-69 1965 1966 1967 $60, 369. 88 87, 992. 10 47, 804. 39
6394r-69 [ 1965 \ 1966 l 1967 7, 282. 63 10, 463. 79 7, 424. 30
6395-69 1965 1966 1967 6, 666. 67 6, 500. 00 6, 500. 00
Concessions have been made by tbe parties, and the issues remaining for decision are as follows:(1) Whether Lewisville Investment Co. and Idaho Fresh-Pak Potatoes, Inc., were organized for the principal purpose of evasion or avoidance of Federal income tax, within the meaning of section 269(a),2 by…
2Cases cited13 opinions
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- Tauber v. CommissionerUnited States Tax Court · 1955
- Aldon Homes, Inc. v. CommissionerUnited States Tax Court · 1959
- California Vegetable Concentrates, Inc. v. CommissionerUnited States Tax Court · 1948
- James Realty Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
8 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- Laure v. CommissionerUnited States Tax Court · 1978
- C. A. White Trucking Co., Inc. And A. F. Crane and Mary L. Crane v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
- Albert Van Luit Co. v. CommissionerUnited States Tax Court · 1975
- Reppel Steel & Supply Co. v. CommissionerUnited States Tax Court · 1976
9 more not listed; retrieve them via the Exa API.