Legal Opinion

Aiken Industries, Inc. v. Commissioner

United States Tax Court

Decided August 5, 1971No. Docket No. 292-69Published

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

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Higgins v. SmithSupreme Court of the United States · 1940
  3. Knetsch v. United StatesSupreme Court of the United States · 1960
  4. Cook v. United StatesSupreme Court of the United States · 1933
  5. Maximov v. United StatesSupreme Court of the United States · 1963

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