Gamble Constr. Co. v. Commissioner
United States Tax Court
(1) On Aug. 14, 1968, X entered into a purchase agreement with the shareholders of Y pursuant to which X purchased 90 percent of Y's stock. Subsequently, Y transferred funds to X, which X used to pay the former shareholders of Y under the purchase agreement. Held, under the facts of this case, the transfers were bona fide loans and not dividends, and therefore X was not subject to the personal holding company tax.
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(1) On Aug. 14, 1968, X entered into a purchase agreement with the shareholders of Y pursuant to which X purchased 90 percent of Y's stock. Subsequently, Y transferred funds to X, which X used to pay the former shareholders of Y under the purchase agreement. Held, under the facts of this case, the transfers were bona fide loans and not dividends, and therefore X was not subject to the personal holding company tax. (2) X and Y entered into a management contract in which X agreed to provide management services for Y in exchange for 50 percent of Y's pre-tax profits. In 1970, an officer of X was…
1Opinion of the Court
GAMBLE CONSTRUCTION CO., INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
INVESTMENT HOLDINGS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gamble Constr. Co. v. Commissioner
Docket Nos. 2022-74, 2023-74.
United States Tax Court
T.C. Memo 1978-404; 1978 Tax Ct. Memo LEXIS 111; 37 T.C.M. (CCH) 1675; T.C.M. (RIA) 78404;
October 10, 1978, Filed(1) On Aug. 14, 1968, X entered into a purchase agreement with the shareholders of Y pursuant to which X purchased 90 percent of Y's stock. Subsequently, Y transferred funds to X, which X used to pay the former shareholders of…
2Cases cited36 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Enoch v. CommissionerUnited States Tax Court · 1972
- Mayson Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
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