Legal Opinion
Fitzgerald Motor Company, Inc., and Loans, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided February 28, 1975No. 74-1291PublishedCited by 20 opinions
1Opinion of the Court
COLEMAN, Circuit Judge.
Pursuant to 26 U.S.C. § 482, the Commissioner of Internal Revenue allocated additional income to Petitioner-Appellants as a result of loans between and among three sister corporations. The taxpayers filed petitions in the United States Tax Court for a redetermination of the assessed deficiencies in taxes for the years 1966 through 1968, totaling $7,874.43. The Tax Court entered judgment against them, 60 T.C. 957 (1973), and this appeal followed. We affirm.
Facts
Taxpayer, Fitzgerald Motor Company, Inc. (Fitzgerald) is a Georgia corporation engaged in the retail sale of…
2Cases cited9 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- PPG Indus., Inc. v. CommissionerUnited States Tax Court · 1970
- Huber Homes, Inc. v. CommissionerUnited States Tax Court · 1971
- The Kahler Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1973
- Tennessee-Arkansas Gravel Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1940
4 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Anderson, Clayton & Co., Plaintiff-Appellee-Cross-Appellant v. United States of America, Defendant-Appellant-Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Continental Equities, Inc., Cross-Appellant v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1977
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- Crown v. CommissionerUnited States Tax Court · 1977
- Edwards v. CommissionerUnited States Tax Court · 1976
15 more not listed; retrieve them via the Exa API.