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MARSHALL INVESTMENT CO., INC. v. COMMISSIONER

Docket No. 3191-71.

32 T.C.M. 382 (1973)

T.C. Memo. 1973-87

Marshall Investment Co., Inc. v. Commissioner.

United States Tax Court.

Filed April 16, 1973.

Attorney(s) appearing for the Case

James M. Parker, 925 Public Serv. Bldg., P.O. Box 925, Albuquerque, N. Mex., for the petitioner. Charles H. Powers, for the respondent.

Memorandum Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioner's income taxes (personal holding company taxes) in the amounts of $414.60 and $2,607.59 for the calendar years 1967 and 1968, respectively.

The issue raised by the pleadings in this case is whether petitioner is subject to the personal holding company tax imposed by section 541, I.R.C. 1954,1 for the years 1967 and 1968.

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