Blue Flame Gas Co. v. Commissioner
United States Tax Court
1. Lessor and its sole shareholder entered into an agreement with lessee whereby the assets of the lessor and assets owned by the shareholder individually were to be leased to lessee for a 10-year period. As part of the same agreement, the lessee agreed to extend a loan to the shareholder of lessor in the amount of the aggregate rental payments due under said leases.
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1. Lessor and its sole shareholder entered into an agreement with lessee whereby the assets of the lessor and assets owned by the shareholder individually were to be leased to lessee for a 10-year period. As part of the same agreement, the lessee agreed to extend a loan to the shareholder of lessor in the amount of the aggregate rental payments due under said leases. Loan repayments coincided exactly in amount and time of payment with the rental payments due under the leases. Held, under the circumstances of this case the purported loan constituted the payment of advance rentals to the lessor…
1Opinion of the Court
Blue Flame Gas Company, Petitioner v. Commissioner of Internal Revenue, Respondent; Joe Zedrick and Estate of Lily Zedrick, Deceased, David J. Zedrick, Administrator, Petitioners v. Commissioner of Internal Revenue, Respondent
Blue Flame Gas Co. v. Commissioner
Docket Nos. 5227-66, 5228-66
United States Tax Court
54 T.C. 584; 1970 U.S. Tax Ct. LEXIS 185;
March 24, 1970, Filed
Decisions will be entered under Rule 50.
1. Lessor and its sole shareholder entered into an agreement with lessee whereby the assets of the lessor and assets owned by the shareholder individually were to be leased to lessee for…
2Cases cited15 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Paymer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1945
- Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
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