Legal Opinion
Rountree Cotton Co. v. Comm'r
United States Tax Court
Decided December 16, 1999No. 24014-97PublishedCited by 5 opinions
1Opinion of the Court
OPINION
Gerber, Judge:
Respondent determined income tax deficiencies in petitioner’s taxable years ended August 31, 1994 and 1995, in the amounts of $19,094 and $16,944, respectively. The deficiencies are attributable to respondent’s determination that petitioner made “below-market loans” within the meaning of section 7872.1 More particularly, we consider a question of first impression of whether the provisions of section 7872 apply where petitioner makes loans to its shareholders and to entities owned in part by its shareholders and in part by other members of the same family.
Background
Petition…
2Cases cited14 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Sullivan v. StroopSupreme Court of the United States · 1990
- Dickman v. CommissionerSupreme Court of the United States · 1984
- Riland v. CommissionerUnited States Tax Court · 1982
9 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Gerdau MacSteel, Inc. & Affiliated Subsidiaries v. CommissionerUnited States Tax Court · 2012
- Barnes v. Comm'rUnited States Tax Court · 2004
- Estate of Hoffman v. Commissioner, IRSCourt of Appeals for the Fourth Circuit · 2001
- Rountree Cotton Co. v. Comm'rUnited States Tax Court · 1999
- Rountree Cotton Co. v. CommissionerUnited States Tax Court · 1999