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HILLDUN CORPORATION v. COMMISSIONER

Docket Nos. 5647-63, 2625-65.

26 T.C.M. 1035 (1967)

T.C. Memo. 1967-210

Hilldun Corporation v. Commissioner.

United States Tax Court.

Filed October 26, 1967.

Attorney(s) appearing for the Case

Earle H. Grossman, for petitioner. Lawrence J. Shongut, for respondent.

Memorandum Findings of Fact and Opinion

ATKINS, Judge:

The respondent determined deficiencies in income tax of $25,263.80 for the taxable year ended August 31, 1960, and $29,208.51 for the taxable year ended August 31, 1961.

The question presented is whether petitioner was a "personal holding company" within the meaning of section 542(a) of the Internal Revenue Code of 1954 for the years in question.<...

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