Aiken Industries, Inc. v. Commissioner
United States Tax Court
Held: 1. Interest paid by a United States corporation to a corporation organized under the laws of Honduras to collect such interest on behalf of a Bahamian corporation was not exempt from United States income tax under art. IX of the United States-Honduras Income Tax Convention. Therefore, petitioner, as successor to the payor, is liable for withholding taxes on such payments. 2. The penalties provided for under sec. 6651(a) for failure to file a return are not applicable.
1Opinion of the Court
Aiken Industries, Inc. (Successor by Merger to Mechanical Products, Inc.), Petitioner v. Commissioner of Internal Revenue, Respondent
Aiken Industries, Inc. v. Commissioner
Docket No. 292-69
United States Tax Court
56 T.C. 925; 1971 U.S. Tax Ct. LEXIS 88;
August 5, 1971, Filed
Decision will be entered under Rule 50.
Held: 1. Interest paid by a United States corporation to a corporation organized under the laws of Honduras to collect such interest on behalf of a Bahamian corporation was not exempt from United States income tax under art. IX of the United States-Honduras Income Tax Convention.…
2Cases cited10 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Cook v. United StatesSupreme Court of the United States · 1933
- Maximov v. United StatesSupreme Court of the United States · 1963
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