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BRAMLETTE BUILDING CORPORATION, INC. v. COMMISSIONER

Docket No. 5920-66.

52 T.C. 200 (1969)

BRAMLETTE BUILDING CORPORATION, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 5, 1969.

Attorney(s) appearing for the Case

John M. Smith, for the petitioner.

Harold L. Cook, for the respondent.

DAWSON, Judge:

Respondent determined income tax deficiencies against petitioner for the years 1963 and 1964 in the respective amounts of $3,250.40 and $2,172.91.

There are three issues for decision: (1) Did petitioner receive more than 20 percent of its gross receipts in 1963 and 1964 from "rents" so that its election to be taxed as a small business corporation under section 13721 terminated? (2) Did petitioner erroneously...

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