Legal Opinion

Allied Industrial Cartage Co. v. Commissioner

United States Tax Court

Decided June 20, 1979No. Docket No. 7918-77Published

Individual A owned 100 percent of the stock of corporate petitioner X and corporation Y. X's principal business was the leasing of real estate and trucks to Y. Held, individual A, through his ownership of Y's stock, will not be treated as an individual entitled to the use of X's property under sec. 543(a)(6), I.R.C. 1954.

1Opinion of the Court

Allied Industrial Cartage Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Allied Industrial Cartage Co. v. Commissioner

Docket No. 7918-77

United States Tax Court

72 T.C. 515; 1979 U.S. Tax Ct. LEXIS 99;

June 20, 1979, Filed

Decision will be entered for the petitioner.

Individual A owned 100 percent of the stock of corporate petitioner X and corporation Y. X's principal business was the leasing of real estate and trucks to Y. Held, individual A, through his ownership of Y's stock, will not be treated as an individual entitled to the use of X's property under sec. 543(a)(6),…

2Cases cited5 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Bartels v. BirminghamSupreme Court of the United States · 1947
  3. Minnesota Mortuaries, Inc. v. CommissionerUnited States Tax Court · 1944
  4. 320 E. 47th Street Corp. v. CommissionerUnited States Tax Court · 1956
  5. Allied Industrial Cartage Co. v. CommissionerUnited States Tax Court · 1979

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