Legal Opinion

Able Metal Products, Inc. v. Commissioner

United States Tax Court

Decided August 31, 1959No. Docket No. 69038PublishedCited by 8 opinions

Held, income received by petitioner in 1954 and 1955 was "personal holding company income" within the meaning of section 543(a)(5), I.R.C. 1954.

1Opinion of the Court

Teetjens, Judge:

The Commissioner determined deficiencies in income tax as follows:

1954_$1, 003.69

1955_ 7,278.13

The only question for decision is whether petitioner derived income in the taxable years under section 543(a) (5), I.R.C. 1954, i.e., “personal holding company income.”

FINDINGS OF FACT.

The stipulated facts are so found and the stipulation is included by this reference.

Petitioner, Able Metal Products, Inc., is an Ohio corporation organized in September 1954, qualified to do business and doing business in the State of Ohio during the years here in question. The corporation ever since…

2Cited by8 opinions

  1. Kurt Frings Agency, Inc. v. CommissionerUnited States Tax Court · 1964
  2. Claggett v. CommissionerUnited States Tax Court · 1965
  3. Thomas P. Byrnes, Inc. v. CommissionerUnited States Tax Court · 1979
  4. Morrison v. CommissionerUnited States Tax Court · 1982
  5. Able Metal Products, Inc. v. CommissionerUnited States Tax Court · 1959

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