Claggett v. Commissioner
United States Tax Court
Petitioner corporation (which was substituted as a partner in a partnership which had, prior to the substitution, consisted of petitioner's organizer-stockholder-president and another) did not receive amounts under a contract under which it was to furnish personal services with some person other than petitioner having the right to designate the individual to perform these services or with the individual to perform the services being designated in the contract, and therefore…
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Petitioner corporation (which was substituted as a partner in a partnership which had, prior to the substitution, consisted of petitioner's organizer-stockholder-president and another) did not receive amounts under a contract under which it was to furnish personal services with some person other than petitioner having the right to designate the individual to perform these services or with the individual to perform the services being designated in the contract, and therefore petitioner is not a personal holding company because of receiving personal holding company income as defined in section…
1Opinion of the Court
S. O. Claggett, Liquidating Trustee for S. O. Claggett, Inc., a Corporation (Dissolved), Petitioner, v. Commissioner of Internal Revenue, Respondent
Claggett v. Commissioner
Docket No. 2471-63
United States Tax Court
44 T.C. 503; 1965 U.S. Tax Ct. LEXIS 63;
June 30, 1965, Filed
Decision will be entered for petitioner.
Petitioner corporation (which was substituted as a partner in a partnership which had, prior to the substitution, consisted of petitioner's organizer-stockholder-president and another) did not receive amounts under a contract under which it was to furnish personal services with some…
2Cases cited7 opinions
- Beck Chemical Equipment Corp. v. CommissionerUnited States Tax Court · 1957
- Mervyn Investment Co. v. BiberCalifornia Supreme Court · 1921
- Wilson v. WilsonCalifornia Court of Appeal · 1950
- Kurt Frings Agency, Inc. v. CommissionerUnited States Tax Court · 1964
- Able Metal Products, Inc. v. CommissionerUnited States Tax Court · 1959
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