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BELL REALTY TRUST v. COMMISSIONER

Docket No. 7601-74.

65 T.C. 766 (1976)

BELL REALTY TRUST, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 21, 1976.

Attorney(s) appearing for the Case

John R. Berman, for the petitioner.

David W. Johnson, for the respondent.

RAUM, Judge:

The Commissioner determined deficiencies of $10,703.71 and $15,324.71 in petitioner's Federal corporate income taxes for the fiscal years ended June 30, 1967, and June 30, 1968, respectively. At issue is whether during each of those years petitioner was a "personal holding company" within the meaning of section 542, I.R.C. 1954, and therefore, subject to the special tax imposed on such corporations by section 541.

FINDINGS OF FACT

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