Pleasanton Gravel Co. v. Commissioner
United States Tax Court
Upon the facts, held: 1. Payments received by a corporation which merged into P constituted royalties and are includable in personal holding company income under sec. 543(a)(3) I.R.C. 1954, rather than being rents excludable under sec. 543(a)(6). 2. Waivers executed by P, as successor in interest to a corporation which merged into P, validly extended the period of limitation on assessment and collection of deficiencies owed by the merged corporation.
1Opinion of the Court
Kórner, Judge:
Respondent determined deficiencies in Federal income tax against Pleasanton Gravel Co., Successor in Interest to Rio Gravel, Inc. (hereinafter petitioner), as follows:
Tax year ended Deficiency
July 31,1968. $6,588
July 31,1969. 13,498
July 31,1970. 12,700
July 31,1971 . 17,233
June 30,1972. 20,616
After concessions, the issues remaining for decision are: (1) Whether, for the taxable years ended July 31, 1968, through June 30, 1972, Rio Gravel, Inc., a corporation which was merged into petitioner, was a personal holding company subject to the personal holding company tax imposed by…
2Cases cited38 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Anderson v. HelveringSupreme Court of the United States · 1940
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Adler v. CommissionerUnited States Tax Court · 1985
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
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