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PARKSIDE, INC. v. C. I. R.

No. 75-2893.

571 F.2d 1092 (1977)

PARKSIDE, INC. and Beaconcrest, Inc., Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

December 2, 1977.

Attorney(s) appearing for the Case

Susan Long (argued), Bellevue, Wash., for petitioners-appellants.

Leonard J. Henzke, Jr. (argued), of Dept. of Justice, Washington, D. C., for respondent-appellee.

Before CHOY and KENNEDY, Circuit Judges, and PREGERSON, District Judge.

CHOY, Circuit Judge:

The Commissioner of Internal Revenue (Commissioner) issued deficiency notices to taxpayer-appellants Parkside, Inc. (Parkside) and Beaconcrest, Inc. (Beaconcrest) upon determining that income reported as interest for certain taxable years brought the two corporations within the rigorous provisions of the personal holding company tax (PHCT), Int.Rev.Code of 1954, §§ 541-47,1 and the Tax Court agreed. We reverse...

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