Lake Gerar Development Co. v. Commissioner
United States Tax Court
Held, interest received on a purchase money mortgage is interest for personal holding company income purposes.
1Opinion of the Court
Irwin, Judge:
Respondent determined deficiencies in income and personal holding company taxes as follows:
Taxable year ended Docket No. Petitioner Deficiency
4/30/72 6940-75 Lake Gerar Development Co. 2$24,773.00
12/31/73 1094r-76 Michael and Peggy Fabrizio 5,914.50
12/31/73 1095-76 Francis J. and Louise Fabrizio 3,763.10
4/26/72 4188-76 Lake Gerar Development Co. alleged transferee of Lake Gerar Hotel Corp. 7,807.45
4/30/73 4189-76 Lake Gerar Development Co. 9,744.01
After concessions by the parties, the only issue3 remaining for our consideration is whether, in docket Nos. 6940-75 and 4188-76, Lake…
2Cases cited4 opinions
- Davenport v. CommissionerUnited States Tax Court · 1978
- O'Sullivan Rubber Co. v. CommissionerUnited States Board of Tax Appeals · 1940
- Bell Realty Trust v. CommissionerUnited States Tax Court · 1976
- West End Co. v. CommissionerUnited States Tax Court · 1955
3Cited by7 opinions
- Pleasant Summit Land Corp. v. CommissionerUnited States Tax Court · 1987
- Krueger Co. v. CommissionerUnited States Tax Court · 1982
- Likins-Foster Honolulu Corp. v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Likins-Foster Honolulu Corp. v. Commissioner Nternal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Investors Ins. Agency, Inc. v. CommissionerUnited States Tax Court · 1979
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