Legal Opinion

Sparks Nugget, Inc. v. Commissioner

United States Tax Court

Decided March 31, 1970No. Docket Nos. 4237-67, 4277-67 - 4280-67UnpublishedCited by 1 opinion

C Corp., SD Corp., and XYZ Corps. were wholly owned by the Graves. C Corp. leased land from SD Corp. and slotmachines from XYZ Corps. Held: (1) C may not deduct, under sec. 162(a)(3),I.R.C. 1954, the amounts paid to SD as rentals, to the extent that such amounts exceed the reasonable rental of the property. (2) The Graves are collaterally estopped from contesting our determination in The Challenger, Inc., 23 T.C.M. 2096, 33 P.-H. Memo.

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C Corp., SD Corp., and XYZ Corps. were wholly owned by the Graves. C Corp. leased land from SD Corp. and slotmachines from XYZ Corps. Held: (1) C may not deduct, under sec. 162(a)(3),I.R.C. 1954, the amounts paid to SD as rentals, to the extent that such amounts exceed the reasonable rental of the property. (2) The Graves are collaterally estopped from contesting our determination in The Challenger, Inc., 23 T.C.M. 2096, 33 P.-H. Memo. T.C. par. 64,338 (1964), of the reasonable monthly rental of each slot machine. 319 (3) Excessive amounts allegedly paid as rental by C to its sister…

1Opinion of the Court

Sparks Nugget, Inc., et al. 1 v. Commissioner.

Sparks Nugget, Inc. v. Commissioner

Docket Nos. 4237-67, 4277-67 - 4280-67.

United States Tax Court

T.C. Memo 1970-74; 1970 Tax Ct. Memo LEXIS 279; 29 T.C.M. (CCH) 318; T.C.M. (RIA) 70074;

March 31, 1970, filed

C Corp., SD Corp., and XYZ Corps. were wholly owned by the Graves. C Corp. leased land from SD Corp. and slotmachines from XYZ Corps. Held: (1) C may not deduct, under sec. 162(a)(3),I.R.C. 1954, the amounts paid to SD as rentals, to the extent that such amounts exceed the reasonable rental of the property.(2) The Graves are collaterally…

2Cases cited47 opinions

  1. Helvering v. HorstSupreme Court of the United States · 1940
  2. Sunshine Anthracite Coal Co. v. AdkinsSupreme Court of the United States · 1940
  3. Edwards v. Cuba RailroadSupreme Court of the United States · 1925
  4. Standard Oil Co. v. MooreCourt of Appeals for the Ninth Circuit · 1957
  5. Thomas Worcester v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1966

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3Cited by1 opinion

  1. Shelley Jou Wienke v. CommissionerUnited States Tax Court · 2020

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