Fidelity Sav. & Loan Co. v. Commissioner
United States Board of Tax Appeals
1. Petitioner in 1936 and 1937 made all mortgage loans except one to borrowers who were not stockholders. Ownership of stock in petitioner is the method of acquiring membership and the terms "member" and "stockholder" mean the same.
Read the full summary
1. Petitioner in 1936 and 1937 made all mortgage loans except one to borrowers who were not stockholders. Ownership of stock in petitioner is the method of acquiring membership and the terms "member" and "stockholder" mean the same. Held, that petitioner is not exempt from Federal income tax under section 101(4) of the Revenue Act of 1936, since substantially all of its business was not confined to making loans to members. 2. Petitioner sold real property acquired through foreclosure, giving a deed and taking a small cash payment, an installment note for the balance, and a purchase money…
1Opinion of the Court
FIDELITY SAVINGS AND LOAN COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Fidelity Sav. & Loan Co. v. Commissioner
Docket Nos. 101236, 101237,
United States Board of Tax Appeals
44 B.T.A. 471; 1941 BTA LEXIS 1327;
May 13, 1941, Promulgated
1. Petitioner in 1936 and 1937 made all mortgage loans except one to borrowers who were not stockholders. Ownership of stock in petitioner is the method of acquiring membership and the terms "member" and "stockholder" mean the same. Held, that petitioner is not exempt from Federal income tax under section 101(4) of the Revenue Act of 1936,…
2Cases cited1 opinion
- Fidelity Sav. & Loan Co. v. CommissionerUnited States Board of Tax Appeals · 1941