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INVESTORS INS. AGENCY, INC. v. C. I. R.

No. 79-7590.

677 F.2d 1328 (1982)

INVESTORS INSURANCE AGENCY, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided May 26, 1982.

Rehearing and Rehearing Denied July 8, 1982.

Attorney(s) appearing for the Case

F. A. LeSourd, Patten, Fleming, Hartung & Emory, Seattle, Wash., for petitioner-appellant.

Robert T. Duffy, Dept. of Justice, Washington, D. C., for respondent-appellee.

Before WRIGHT and NORRIS, Circuit Judges, and HATFIELD, District Judge.

Rehearing and Rehearing En Banc Denied July 8, 1982.

EUGENE A. WRIGHT, Circuit Judge:

The Commissioner of Internal Revenue (Commissioner) assessed Investors Insurance Agency, Inc. (Taxpayer) with a deficiency when it determined that $130,000 interest received by taxpayer in 1974 triggered the provisions of the personal holding company tax. 26 U.S.C. § 541. The Tax Court affirmed the deficiency assessment, rejecting taxpayer's argument that the $130,000...

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