Liberty Finance Service, Inc. v. Commissioner
United States Tax Court
Petitioner, a licensed personal finance company, derived more than 80 per cent of its gross income from interest. More than 80 per cent of such interest received by petitioner exceeded the lawful rate in Alabama. More than 50 per cent in value of petitioner's outstanding stock was owned by not more than five individuals.
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Petitioner, a licensed personal finance company, derived more than 80 per cent of its gross income from interest. More than 80 per cent of such interest received by petitioner exceeded the lawful rate in Alabama. More than 50 per cent in value of petitioner's outstanding stock was owned by not more than five individuals. Petitioner borrowed certain funds from members of the general public, from its shareholders and officers, and from a bank, for which it issued interest-bearing notes having a fixed maturity date. Held: Petitioner is a personal holding company subject to personal holding…
1Opinion of the Court
Fisher, Judge:
This case involves deficiencies in personal holding company surtax determined by respondent as follows:
Tear ended, Oct. SI— Amount
1950_$2, 612. TS
1951_ 6,123.41
1952_ 5, 686.76
1953_ 6,292.10
The sole issue presented is whether petitioner is entitled to exemption from personal holding company surtax under section 501(b) (T) of the Code of 1989.
BINDINGS OK PACT.
The stipulated facts are so found, and are incorporated herein by reference.
Liberty Finance Service, Inc., hereinafter referred to as petitioner, was incorporated under the laws of Alabama on November 8, 1948, and was, during…
2Cases cited11 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- D. Ginsberg & Sons, Inc. v. PopkinSupreme Court of the United States · 1932
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- Bachmura v. CommissionerUnited States Tax Court · 1959
- McCamant v. CommissionerUnited States Tax Court · 1959
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3Cited by7 opinions
- Essenfeld v. CommissionerUnited States Tax Court · 1961
- Energy Resources, Ltd. v. CommissionerUnited States Tax Court · 1988
- Jos. K., Inc. v. CommissionerUnited States Tax Court · 1969
- Energy Resources, Ltd. v. CommissionerUnited States Tax Court · 1988
- Essenfeld v. CommissionerUnited States Tax Court · 1961
2 more not listed; retrieve them via the Exa API.