Krueger Co. v. Commissioner
United States Tax Court
Petitioner made interest-free loans to corporations controlled by common interests. The Commissioner allocated interest on the loans under sec. 482, I.R.C. 1954, which resulted in the imposition of personal holding company tax under sec. 541, I.R.C. 1954, upon the lender. Held, interest allocated under sec. 482 constitutes interest for purposes of the personal holding company tax provisions and the lender corporation is liable for personal holding company tax.
1Opinion of the Court
OPINION
Goffe, Judge:
The Commissioner determined deficiencies in the Federal income tax of Krueger Bros., Inc.,1 for the following years and in the following amounts:
Taxable year Deficiency
1974 .$5,756
1975 . 4,131
The adjustments giving rise to these deficiencies have been conceded by petitioners.
The Commissioner determined deficiencies in the Federal income tax and personal holding company tax of the petitioner, Krueger Co., Inc., for the following years and in the following amounts:
TYE June 30— Deficiency
1975 .$34,678
1976 . 23,932
1977 . 22,658
After concessions by the parties, the only…
2Cases cited8 opinions
- Lang v. CommissionerSupreme Court of the United States · 1933
- Huber Homes, Inc. v. CommissionerUnited States Tax Court · 1971
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- Edwards v. CommissionerUnited States Tax Court · 1976
- Investors Insurance Agency, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
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3Cited by5 opinions
- Likins-Foster Honolulu Corp. v. CommissionerUnited States Tax Court · 1985
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- Likins-Foster Honolulu Corp. v. Commissioner Nternal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Friendly Finance, Inc. v. CommissionerUnited States Tax Court · 1991
- Krueger Co. v. CommissionerUnited States Tax Court · 1982