Legal Opinion

H Enters. Int'l v. Commissioner

United States Tax Court

Decided March 9, 1998No. Tax Ct. Dkt. No. 11478-93UnpublishedCited by 3 opinions

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

  1. John E. Leslie and Evelyn G. Leslie v. Commissioner of the Internal RevenueCourt of Appeals for the Second Circuit · 1969
  2. Illinois Terminal Railroad Company v. The United StatesUnited States Court of Claims · 1967
  3. Leslie v. CommissionerUnited States Tax Court · 1968
  4. H Enters. Int'l v. CommissionerUnited States Tax Court · 1995
  5. Bradford v. CommissionerUnited States Tax Court · 1973

4 more not listed; retrieve them via the Exa API.

3Cited by3 opinions

  1. H Enterprises International, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1999
  2. H Enterprises Intl. v. CIRCourt of Appeals for the Eighth Circuit · 1999
  3. OBH, Inc. v. United StatesDistrict Court, D. Nebraska · 2005

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