Legal Opinion

Liberty Finance Service, Inc. v. Commissioner

United States Tax Court

Decided July 11, 1960No. Docket No. 62634Published

Petitioner, a licensed personal finance company, derived more than 80 per cent of its gross income from interest. More than 80 per cent of such interest received by petitioner exceeded the lawful rate in Alabama. More than 50 per cent in value of petitioner's outstanding stock was owned by not more than five individuals.

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Petitioner, a licensed personal finance company, derived more than 80 per cent of its gross income from interest. More than 80 per cent of such interest received by petitioner exceeded the lawful rate in Alabama. More than 50 per cent in value of petitioner's outstanding stock was owned by not more than five individuals. Petitioner borrowed certain funds from members of the general public, from its shareholders and officers, and from a bank, for which it issued interest-bearing notes having a fixed maturity date. Held: Petitioner is a personal holding company subject to personal holding…

1Opinion of the Court

Liberty Finance Service, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Liberty Finance Service, Inc. v. Commissioner

Docket No. 62634

United States Tax Court

34 T.C. 682; 1960 U.S. Tax Ct. LEXIS 108;

July 11, 1960, Filed

Decision will be entered under Rule 50.

Petitioner, a licensed personal finance company, derived more than 80 per cent of its gross income from interest. More than 80 per cent of such interest received by petitioner exceeded the lawful rate in Alabama. More than 50 per cent in value of petitioner's outstanding stock was owned by not more than five individuals.…

2Cases cited12 opinions

  1. Putnam v. CommissionerSupreme Court of the United States · 1956
  2. D. Ginsberg & Sons, Inc. v. PopkinSupreme Court of the United States · 1932
  3. Commissioner v. JacobsonSupreme Court of the United States · 1949
  4. Bachmura v. CommissionerUnited States Tax Court · 1959
  5. McCamant v. CommissionerUnited States Tax Court · 1959

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