Blair Holding Co. v. Commissioner
United States Tax Court
Held: Interest payments received by petitioner from a related corporation under a claim of right were includable in its gross income thereby subjecting petitioner to the personal holding company tax; petitioner was not a mere conduit or nominee. Bell Realty Trust v. Commissioner,65 T.C. 766 (1976) followed.
1Opinion of the Court
BLAIR HOLDING CO., INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Blair Holding Co. v. Commissioner
Docket No. 11203-76.
United States Tax Court
T.C. Memo 1980-79; 1980 Tax Ct. Memo LEXIS 506; 39 T.C.M. (CCH) 1255; T.C.M. (RIA) 80079;
March 19, 1980, Filed
Held: Interest payments received by petitioner from a related corporation under a claim of right were includable in its gross income thereby subjecting petitioner to the personal holding company tax; petitioner was not a mere conduit or nominee. Bell Realty Trust v. Commissioner,65 T.C. 766 (1976) followed.
Joseph Schoenholz, for…
2Cases cited1 opinion
- Bell Realty Trust v. CommissionerUnited States Tax Court · 1976