Legal Opinion
Melinda L. Gee Trust v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 28, 1985No. 84-7405 to 84-7409, 84-7412PublishedCited by 7 opinions
1Per curiam
Appellants are successors-in-interest and transferees of two United States corporations, International Food Technology Service, Inc. (IFTS) and L.F.G., Inc. (LFG). During 1973 and 1974, IFTS and LFG were major shareholders of Simarloo Pty., Ltd., an Australian corporation. During the fiscal year ending June 30, 1973, Simarloo realized capital gains on the sale of certain stock. Simarloo did not distribute this profit to its shareholders.
The Commissioner determined that Si-marloo was a foreign personal holding company under 26 U.S.C. §§ 551-556 for the 1973 fiscal year. Accordingly, pursuant…
2Cases cited1 opinion
- Mariani Frozen Foods, Inc. v. CommissionerUnited States Tax Court · 1983
3Cited by7 opinions
- J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
- Metro Leasing & Dev. Corp. v. Comm'rUnited States Tax Court · 2002
- Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
- Framatome Connectors USA, Inc. v. CommissionerUnited States Tax Court · 2002
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