Seagrave Corp. v. Commissioner
United States Tax Court
Held, volunteer fire companies are not political subdivisions of States where they are located and interest on their obligations is not tax-exempt interest income under section 103(a)(1), I.R.C. 1954.
1Opinion of the Court
Mulroney, Judge:
The respondent determined a deficiency in petitioner’s income tax for the taxable year 1955 in the amount of $36,985.90. All issues have been settled with the exception of one issue as to whether interest accrued to petitioner in the amount of $1,968.28 on obligations issued by six volunteer fire departments is exempt from gross income under section 103(a) (1), I.R.C. 1954.1
FINDINGS OF FACT.
Some of the facts have been stipulated and are found accordingly.
Petitioner is a corporation with its principal office at 2000 South High Street, Columbus, Ohio. Its return for the year…
2Cases cited5 opinions
- Commissioner of Internal Revenue v. Shamberg's EstateCourt of Appeals for the Second Circuit · 1944
- Commissioner of Internal Revenue v. White's EstateCourt of Appeals for the Second Circuit · 1944
- National Engraving Co. v. CommissionerUnited States Tax Court · 1944
- Shamberg v. CommissionerUnited States Tax Court · 1944
- White v. CommissionerUnited States Tax Court · 1944
3Cited by6 opinions
- Texas Learning Technology Group v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1992
- Philadelphia National Bank and Philadelphia National Corporation v. United StatesCourt of Appeals for the Third Circuit · 1981
- Seagrave Corp. v. CommissionerUnited States Tax Court · 1962
- State of Michigan and Michigan Education Trust v. United StatesCourt of Appeals for the Sixth Circuit · 1995
- State of Michigan and Michigan Education Trust v. United StatesCourt of Appeals for the Sixth Circuit · 1995
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