Latham Park Manor, Inc. v. Commissioner
United States Tax Court
Held: Sec. 482, I.R.C. 1954, as amplified by secs. 1.482-1(d)(4) and 1.482-2(a)(1), Income Tax Regs., adopted in 1968, permits the allocation of interest income to two subsidiary corporations in respect of interest-free loans they made to their parent corporation, even though the parent corporation did not use the loan proceeds to produce income during the taxable years.
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Held: Sec. 482, I.R.C. 1954, as amplified by secs. 1.482-1(d)(4) and 1.482-2(a)(1), Income Tax Regs., adopted in 1968, permits the allocation of interest income to two subsidiary corporations in respect of interest-free loans they made to their parent corporation, even though the parent corporation did not use the loan proceeds to produce income during the taxable years. To the extent inconsistent with this opinion, Smith-Bridgman & Co. v. Commissioner, 16 T.C. 287 (1951); PPG Industries, Inc. v. Commissioner, 55 T.C. 928 (1970); Kerry Investment Co. v. Commissioner, 58 T.C. 479 (1972), affd.…
1Opinion of the Court
Latham Park Manor, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Lindley Park Manor, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Latham Park Manor, Inc. v. Commissioner
Docket Nos. 2339-76, 2340-76
United States Tax Court
69 T.C. 199; 1977 U.S. Tax Ct. LEXIS 27;
November 9, 1977, Filed
Decisions will be entered under Rule 155.
Held: Sec. 482, I.R.C. 1954, as amplified by secs. 1.482-1(d)(4) and 1.482-2(a)(1), Income Tax Regs., adopted in 1968, permits the allocation of interest income to two subsidiary corporations in respect of interest-free loans they made…
Also in this document: Concurrence.
2Cases cited39 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Helvering v. GowranSupreme Court of the United States · 1937
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
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