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PAN AMERICAN ACCEPTANCE CORPORATION v. COMMISSIONER

Docket No. 16726-85.

57 T.C.M. 1360 (1989)

T.C. Memo. 1989-440

Pan American Acceptance Corporation v. Commissioner.

United States Tax Court.

Filed August 21, 1989.

Attorney(s) appearing for the Case

Juan F. Vasquez and Linda M. Drozd (specially recognized), 3003 N.W. Loop 410, San Antonio, Tex., for the petitioner. David H. Peck and David E. Whitcomb, for the respondent.

Memorandum Findings of Fact and Opinion

JACOBS, Judge:

Respondent determined a deficiency of $34,355.50 in petitioner's income tax for the taxable year 1982.

The issue for decision is whether petitioner qualifies under section 542(c)(6)1 for the lending or finance company exception to personal holding company classification. To resolve this issue, we must decide whether a $26,000 withdrawal from petitioner by Donate Cangelosi...

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