AUDREY REALTY, INC. v. COMMISSIONER

Docket No. 5076-66.

50 T.C. 583 (1968)

AUDREY REALTY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 18, 1968.


Attorney(s) appearing for the Case

Philip M. Hak, for the petitioner.

Lawrence A. Wright, for the respondent.


OPINION

TIETJENS, Judge:

The Commissioner determined a deficiency of $7,745.07 in income tax against petitioner for the taxable year ending December 31, 1964.

The basic question is whether or not petitioner was a "personal holding company" in 1964. In the present context this depends upon whether petitioner, which conducted a loan business, the loans of which were secured by real estate mortgages,...

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