determining whether a small loan company, Greenbelt Finance, Inc., was "largely an operating company" under sec. 1.1244(c)-1(g)(2), Income Tax Regs.↩
How later courts described this case
- determining whether a small loan company, Greenbelt Finance, Inc., was "largely an operating company" under sec. 1.1244(c)-1(g)(2), Income Tax Regs.↩
- not credible that taxpayer would spend $130,000.00 on stock and loans to protect $7,200.00 in pre-tax income
Written by the judges who cited it.
The opinion
Tannenwald, /., concurring: The parties in this case have focussed on the question whether respondent’s regulation qualifying section 1244(c)(1)(E), and particularly its exception clause in respect of largely operating companies, is valid. In this focus, I have no doubt that the majority herein is correct. I reserve my position in a future case where the parties lock horns on whether a small loan company can be considered a “largely operating company” within the meaning of respondent’s regulations and there is an adequate record upon which to make a determination of that issue.
Raum and Simpson, JJ., agree with this concurring opinion.