Legal Opinion

Pleasanton Gravel Co. v. Commissioner

United States Tax Court

Decided November 25, 1985No. Docket No. 22723-81Published

Upon the facts, held: 1. Payments received by a corporation which merged into P constituted royalties and are includable in personal holding company income under sec. 543(a)(3) I.R.C. 1954, rather than being rents excludable under sec. 543(a)(6). 2. Waivers executed by P, as successor in interest to a corporation which merged into P, validly extended the period of limitation on assessment and collection of deficiencies owed by the merged corporation.

1Opinion of the Court

Pleasanton Gravel Co., Successor in Interest to Rio Gravel, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Pleasanton Gravel Co. v. Commissioner

Docket No. 22723-81

United States Tax Court

85 T.C. 839; 1985 U.S. Tax Ct. LEXIS 15; 85 T.C. No. 49;

November 25, 1985, Filed

Decision will be entered for the respondent.

Upon the facts, held:

1. Payments received by a corporation which merged into P constituted royalties and are includable in personal holding company income under sec. 543(a)(3) I.R.C. 1954, rather than being rents excludable under sec. 543(a)(6).

2. Waivers executed by P,…

2Cases cited40 opinions

  1. Crane v. CommissionerSupreme Court of the United States · 1947
  2. Anderson v. HelveringSupreme Court of the United States · 1940
  3. Huntsberry v. CommissionerUnited States Tax Court · 1984
  4. Adler v. CommissionerUnited States Tax Court · 1985
  5. Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978

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