Jos. K., Inc. v. Commissioner
United States Tax Court
Petitioner was a loan company incorporated in California, on Apr. 23, 1959, with an initial capitalization of $ 1,500. Ninety-nine percent of the issued and outstanding stock was owned by Joseph K. Stanley, petitioner's president, and his wife, Ernestine. At the time of petitioner's incorporation, assets (primarily in the form of notes receivable) were transferred to petitioner from another corporation controlled by Joseph K. Stanley.
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Petitioner was a loan company incorporated in California, on Apr. 23, 1959, with an initial capitalization of $ 1,500. Ninety-nine percent of the issued and outstanding stock was owned by Joseph K. Stanley, petitioner's president, and his wife, Ernestine. At the time of petitioner's incorporation, assets (primarily in the form of notes receivable) were transferred to petitioner from another corporation controlled by Joseph K. Stanley. During 4 years of corporate life, more than 80 percent of petitioner's income in each year was interest from the notes transferred to it or from notes…
1Opinion of the Court
Jos. K., Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Jos. K., Inc. v. Commissioner
Docket No. 3961-65
United States Tax Court
51 T.C. 584; 1969 U.S. Tax Ct. LEXIS 210;
January 13, 1969, Filed
Decision will be entered for the respondent.
Petitioner was a loan company incorporated in California, on Apr. 23, 1959, with an initial capitalization of $ 1,500. Ninety-nine percent of the issued and outstanding stock was owned by Joseph K. Stanley, petitioner's president, and his wife, Ernestine. At the time of petitioner's incorporation, assets (primarily in the form of notes…
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