J. William Frentz v. Commissioner of Internal Revenue

Sixth Circuit

J. William Frentz v. Commissioner of Internal Revenue

375 F.2d 662, 19 A.F.T.R.2d (RIA) 1194, 1967 U.S. App. LEXIS 7179

CourtCourt of Appeals for the Sixth Circuit

DecidedMarch 7, 1967

Docket16946

StatusPublished

Cited by70 cases

This text of 375 F.2d 662 (J. William Frentz v. Commissioner of Internal Revenue) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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J. William Frentz v. Commissioner of Internal Revenue, 375 F.2d 662, 19 A.F.T.R.2d (RIA) 1194, 1967 U.S. App. LEXIS 7179 (6th Cir. 1967).

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Opinion

ORDER.

Petitioners claimed as deductions in their 1960 income tax returns their pro rata shares of losses sustained by Ken-tuckiana Broadcasting, Inc., an electing small business corporation under Sub-chapter S of the Internal Revenue Code of 1954, during the fiscal year ending October 31, 1960. The required election in the name of Kentuckiana was filed by petitioners, along with their consent as shareholders, on November 30, 1959. Kentuckiana’s charter was issued by the State of Kentucky subsequent to the purported election, and respondent disallowed the claimed deductions. From an adverse decision by the Tax Court petitioners appeal.

It being the opinion of the Court that the findings of fact by the Tax Court are not clearly erroneous, and that the ruling by the Tax Court that there must be “strict compliance” with the statutory requirements is correct,

It is ordered that the decision of the Tax Court, entered June 28, 1965, be and hereby is affirmed for the reasons set forth in Judge Bruce’s opinion, reported in 44 T.C. 485.

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ORDER.

Petitioners claimed as deductions in their 1960 income tax returns their pro rata shares of losses sustained by Ken-tuckiana Broadcasting, Inc., an electing small business corporation under Sub-chapter S of the Internal Revenue Code of 1954, during the fiscal year ending October 31, 1960. The required election in the name of Kentuckiana was filed by petitioners, along with their consent as shareholders, on November 30, 1959. Kentuckiana’s charter was issued by the State of Kentucky subsequent to the purported election, and respondent disallowed the claimed deductions. From an adverse decision by the Tax Court petitioners appeal.

It being the opinion of the Court that the findings of fact by the Tax Court are not clearly erroneous, and that the ruling by the Tax Court that there must be “strict compliance” with the statutory requirements is correct,

It is ordered that the decision of the Tax Court, entered June 28, 1965, be and hereby is affirmed for the reasons set forth in Judge Bruce’s opinion, reported in 44 T.C. 485.

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375 F.2d 662, 19 A.F.T.R.2d (RIA) 1194, 1967 U.S. App. LEXIS 7179, Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-william-frentz-v-commissioner-of-internal-revenue-ca6-1967.

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