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INVESTORS INSURANCE AGENCY, INC. v. COMMISSIONER

Docket No. 4457-78.

72 T.C. 1027 (1979)

INVESTORS INSURANCE AGENCY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 10, 1979.

Attorney(s) appearing for the Case

F. A. LeSourd, Meade Emory, and Rodney J. Waldbaum, for the petitioner.

Thomas N. Tomashek, for the respondent.

OPINION

NIMS, Judge:

Respondent has determined an income tax deficiency of $29,434 for the calendar year 1974. The sole issue for determination is whether the sum of $130,000 received by petitioner during 1974 constitutes "interest," thereby subjecting petitioner to the personal holding company tax under section 541.1

The facts in this case were fully stipulated. The stipulation of facts and attached exhibits are...

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