Texas Trade School v. Commissioner
United States Tax Court
Petitioner paid excessive rentals to a dominant group of persons which managed its affairs, and it made valuable improvements upon the real estate owned by such persons. Held, that it failed to qualify as a corporation "no part of the net earnings of which inures to the benefit of any private shareholder or individual." Sec. 101 (6), I. R. C. 1939.
1Opinion of the Court
The respondent determined deficiencies in income tax of petitioner for the fiscal years ending May 31, 1947, and May 31, 1948, in the amounts of $302.53 and $2,007.14, respectively.
The sole issue is whether the petitioner is entitled to exemption from tax for the taxable years under section 101 (6) of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
Some of the facts have been stipulated and they are incorporated herein by reference.
Petitioner is a corporation chartered by the secretary of state of Texas on February 27, 1946. Its officers during the major portion of the period from its…
2Cited by16 opinions
- Hancock Academy of Savannah, Inc. v. CommissionerUnited States Tax Court · 1977
- Knollwood Memorial Gardens v. CommissionerUnited States Tax Court · 1966
- F. E. McGillick Co. v. CommissionerUnited States Tax Court · 1958
- Texas Trade School v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Rose Hill Memorial Park, Inc. v. CommissionerUnited States Tax Court · 1964
11 more not listed; retrieve them via the Exa API.