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
The Krueger Co., Inc., and Merri Mac Corp. (formerly known as M.K.B. Corp.) as successor (by statutory merger) to Krueger Bros., Inc., Petitioners v. Commissioner of Internal Revenue, Respondent
Krueger Co. v. Commissioner
Docket No. 15891-80
United States Tax Court
79 T.C. 65; 1982 U.S. Tax Ct. LEXIS 66; 79 T.C. No. 3;
July 14, 1982, Filed
Decision will be entered under Rule 155.
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…
2Cases cited9 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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