Medical-Surgical Group, Inc. v. Commissioner
United States Tax Court
Personal Holding Company Income -- Sec. 502(f), I.R.C. 1939. -- Nine doctors and one dentist formed corporation to construct building for use as doctors' offices and related uses, each subscribing to one-tenth of the total stock outstanding. The nine doctor-stockholders also formed a partnership to conduct an X-ray and medical laboratory in the building.
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Personal Holding Company Income -- Sec. 502(f), I.R.C. 1939. -- Nine doctors and one dentist formed corporation to construct building for use as doctors' offices and related uses, each subscribing to one-tenth of the total stock outstanding. The nine doctor-stockholders also formed a partnership to conduct an X-ray and medical laboratory in the building. The gross income of the corporation consisted of a small amount of interest plus rent from a pharmacy operated by a nonstockholder, from the dentist-stockholder who was not a partner, from the partnership, and from each of the nine…
1Opinion of the Court
Medical-Surgical Group, Inc., a Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent
Medical-Surgical Group, Inc. v. Commissioner
Docket No. 68790
United States Tax Court
33 T.C. 888; 1960 U.S. Tax Ct. LEXIS 204;
February 16, 1960, Filed
Decision will be entered for the petitioner.
Personal Holding Company Income -- Sec. 502(f), I.R.C. 1939. -- Nine doctors and one dentist formed corporation to construct building for use as doctors' offices and related uses, each subscribing to one-tenth of the total stock outstanding. The nine doctor-stockholders also formed a partnership to…
2Cases cited13 opinions
- Hatfried, Inc. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1947
- J. D. Abbott and Kathryn Abbott v. Commissioner of Internal Revenue, Carl M. Wolfe and Mary E. Wolfe v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Abbott v. CommissionerUnited States Tax Court · 1957
- Davis v. CommissionerUnited States Tax Court · 1956
- Randolph Products Co. v. ManningCourt of Appeals for the Third Circuit · 1949
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