THE VALLEY CAMP COAL COMPANY, PETITIONER,
v.
COMMISSIONER OF INTERNAL REVENUE, RESPONDENT
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The Tax Court's findings of fact and inferences drawn therefrom were not clearly erroneous.
Petitioner leased and then purchased mineral rights, using a subsidiary as a conduit for payment and title holding. The Tax Court found the sole purpo…
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PER CURIAM.
The petitioner was the lessee of the mineral rights of the Alexander Mine in Marshall County, West Virginia. After operating this mine, the petitioner subsequently purchased the mine from the owner-lessor, utilizing its wholly owned subsidiary as a conduit for payment of the purchase price and to hold the legal title. The Tax Court found that no valid business purpose was served by allowing the subsidiary to hold the legal title and that the sole purpose of handling the transaction in this manner was tax avoidance.
We hold that the findings of fact and the inferences drawn therefrom by the Tax Court are not clearly erroneous. Commissioner of Internal Revenue v. Duberstein, 363 U.S. 278, 80 S.Ct. 1190, 4 L.Ed.2d 1218.
The judgment of the Tax Court is affirmed upon the memorandum opinion of that Court prepared by Judge Harron. T.C.Memo 1967—225; Commissioner of Internal Revenue v. Court Holding Co., 324 U.S. 331, 65 S.Ct. 707, 89 L.Ed. 981; Ach v. Commissioner of Internal Revenue, 358 F. 2d 342 (6th Cir.).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Commissioner of Internal Revenue v. Duberstein et ux., 363 U.S. 278 (U.S. 1960)
- Commissioner of Internal Revenue v. Court Holding Co., 324 U.S. 331 (U.S. 1945)
- ACH v. Commissioner OF Internal Revenue, 358 F.2d 342 (6th Cir. 1966)