Omaha Aircraft Leasing Co. v. Commissioner
United States Tax Court
Petitioner, a finance company, had in earlier years made aircraft loans to customers of petitioner's sister corporation. During all of the 3 years in issue, however, none of these loans remained, and petitioner's sole lending activities and income were from loans to Sky Harbor and two other sister corporations.
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Petitioner, a finance company, had in earlier years made aircraft loans to customers of petitioner's sister corporation. During all of the 3 years in issue, however, none of these loans remained, and petitioner's sole lending activities and income were from loans to Sky Harbor and two other sister corporations. Held: On the facts, petitioner did not, during the years in issue, derive income "from the active and regular conduct of a lending or finance business" within the meaning of sec. 542(c)(6)(A), I.R.C. 1954, and could not, therefore, qualify for the financing company exception to…
1Opinion of the Court
Omaha Aircraft Leasing Co., Petitioner v. Commissioner of Internal Revenue, Respondent
Omaha Aircraft Leasing Co. v. Commissioner
Docket No. 1437-78
United States Tax Court
74 T.C. 251; 1980 U.S. Tax Ct. LEXIS 137;
May 13, 1980, Filed
Decision will be entered for the respondent.
Petitioner, a finance company, had in earlier years made aircraft loans to customers of petitioner's sister corporation. During all of the 3 years in issue, however, none of these loans remained, and petitioner's sole lending activities and income were from loans to Sky Harbor and two other sister corporations. Held: On the…
2Cases cited7 opinions
- Imel v. CommissionerUnited States Tax Court · 1973
- Commissioner of Internal Revenue v. Marne S. Wilson, Marjorie M. Wilson, Lyle C. Wilson and Peggy WilsonCourt of Appeals for the Ninth Circuit · 1965
- Davenport v. CommissionerUnited States Tax Court · 1978
- Wilson v. CommissionerUnited States Tax Court · 1964
- Hanson v. United StatesDistrict Court, D. Montana · 1971
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