H Enters. Int'l v. Commissioner
United States Tax Court
W II, a subsidiary of HEI, borrowed funds, a part of which was distributed to HEI with respect to its stock in W II. HEI used a portion of the distribution to buy portfolio stock and tax-exempt obligations and held such stock and obligations for the 3 tax years in issue.
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W II, a subsidiary of HEI, borrowed funds, a part of which was distributed to HEI with respect to its stock in W II. HEI used a portion of the distribution to buy portfolio stock and tax-exempt obligations and held such stock and obligations for the 3 tax years in issue. HELD: the indebtedness was incurred to purchase tax-exempt obligations for the purpose of sec. 265(a)(2), I.R.C., and is directly attributable to the acquisition of portfolio stock for the purpose of sec. 246A, I.R.C.; respondent's disallowances of an interest deduction pursuant to sec. 265(a)(2), I.R.C. and of a dividend…
1Opinion of the Court
H ENTERPRISES INTERNATIONAL, INC., AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
H Enters. Int'l v. Commissioner
Tax Ct. Dkt. No. 11478-93
United States Tax Court
T.C. Memo 1998-97; 1998 Tax Ct. Memo LEXIS 97; 75 T.C.M. (CCH) 1948; T.C.M. (RIA) 98097;
March 9, 1998, Filed
Decision will be entered under Rule 155.
W II, a subsidiary of HEI, borrowed funds, a part of which was distributed to HEI with respect to its stock in W II. HEI used a portion of the distribution to buy portfolio stock and tax-exempt obligations and held such stock and obligations for the 3 tax years…
2Cases cited9 opinions
- John E. Leslie and Evelyn G. Leslie v. Commissioner of the Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Illinois Terminal Railroad Company v. The United StatesUnited States Court of Claims · 1967
- Leslie v. CommissionerUnited States Tax Court · 1968
- H Enters. Int'l v. CommissionerUnited States Tax Court · 1995
- Bradford v. CommissionerUnited States Tax Court · 1973
4 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
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- H Enterprises Intl. v. CIRCourt of Appeals for the Eighth Circuit · 1999
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