Bell Realty Trust v. Commissioner
United States Tax Court
Held, T corp. was not a mere conduit in respect of certain interest payments received by it; such payments were includable in its own "gross income," with the consequence that it qualified as a personal holding company under sec. 542, I.R.C. 1954, and thereby became subject to the special tax imposed by sec. 541 on its undistributed personal holding company income.
1Opinion of the Court
Bell Realty Trust, Petitioner v. Commissioner of Internal Revenue, Respondent
Bell Realty Trust v. Commissioner
Docket No. 7601-74
United States Tax Court
65 T.C. 766; 1976 U.S. Tax Ct. LEXIS 175;
January 21, 1976, Filed
Decision will be entered for the respondent.
Held, T corp. was not a mere conduit in respect of certain interest payments received by it; such payments were includable in its own "gross income," with the consequence that it qualified as a personal holding company under sec. 542, I.R.C. 1954, and thereby became subject to the special tax imposed by sec. 541 on its undistributed…
2Cases cited12 opinions
- O'Sullivan Rubber Co. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1941
- Pleasanton Gravel Co. v. CommissionerUnited States Tax Court · 1975
- Coshocton Sec. Co. v. CommissionerUnited States Tax Court · 1956
- Cedarburg Canning Co. v. Commissioner of Int. Rev.Court of Appeals for the Seventh Circuit · 1945
- American Package Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1942
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