# Davenport v. Commissioner

> United States Tax Court · September 14, 1978 · 70 T.C. 922

URL: https://www.frixlaw.com/law-library/cases/4483809

## Case

- **Full name:** H. L. Davenport and Neysa C. Davenport v. Commissioner of Internal Revenue
- **Court:** United States Tax Court
- **Decided:** September 14, 1978
- **Citations:** 70 T.C. 922; 1978 U.S. Tax Ct. LEXIS 57
- **Precedential status:** Published
- **Opinion:** Concurrence by Tannenwald
- **Judges:** Wiles,Tannenwald,Raum,Simpson,Featherston,Drennen,Fay,Sterrett,Goffe,Hall,Wilbur,Drennen,Goffe
- **Cited by:** 14 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4483809

## Opinion text

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.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4483809. Public record. Not legal advice.