Legal Opinion
Hilldun Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided April 2, 1969No. 248, Docket 32610PublishedCited by 6 opinions
1Opinion of the Court
HAYS, Circuit Judge:
Taxpayer appeals from a decision of the Tax Court, 26 CCH Tax Ct.Mem. 1035 (1967), determining a deficiency in its income tax payments for the year ended August 31, 1960 1 on the ground that it was taxable as a personal holding company under Section 541 of the Internal Revenue Code of 1954 as then in effect, ch. 736, § 541, 68A Stat. 182. During this year taxpayer was engaged in a real estate business and in a financing business.
I
Taxpayer’s liability for the personal holding company tax turns, first, on whether rental income constituted 50% or more of its gross income. If…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Television Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
- Arthur F. Brook and Ruth T. Brook v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Wire-O Binding Company, Inc.Court of Appeals for the Second Circuit · 1966
- 320 East 47th Street Corp. v. CommissionerCourt of Appeals for the Second Circuit · 1957
3Cited by6 opinions
- Susie Salvatore v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Buckeye Power, Inc. v. United StatesUnited States Court of Federal Claims · 1997
- Silverman & Sons Realty Trust v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1980
- Likins-Foster Honolulu Corp. v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Allied Industrial Cartage Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981
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