PRODUCERS REALTY CORP. v. COMMISSIONER

Docket No. 89851.

21 T.C.M. 900 (1962)

T.C. Memo. 1962-162

Producers Realty Corp. v. Commissioner.

United States Tax Court.

Filed June 29, 1962.


Attorney(s) appearing for the Case

George M. Mott, Esq., 632 Illinois Bldg., Indianapolis, Ind., for the petitioner. George H. Becker, Esq., for the respondent.


Memorandum Opinion

FORRESTER, Judge:

Respondent determined deficiencies in petitioner's income tax for the taxable years 1957 and 1958 of $6,000.34 and $5,275.90, respectively. The only issue is whether certain payments to petitioner were interest, thereby subjecting it to the personal holding company tax imposed by section 541 of the Internal Revenue Code of 1954.1

All of the facts have been stipulated and are so found...

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