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Mazo v. Commissioner

T.C. Memo. 1973-125 (1973)

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Mazo v. Commissioner

United States Tax Court

T.C. Memo. 1973-125 (1973)

Facts

Savannah Inn and Country Club, Inc. (Savannah) had 15 stockholders when it decided that it needed additional cash to continue operating. Savannah’s board tried to require all of its stockholders to contribute, but five stockholders refused. It was determined that these five stockholders would exchange their stock for interest-bearing debt instruments. After this exchange, the five stockholders ceased participating in any of Savannah’s corporate affairs or its management. Later, Savannah filed an election to be taxed as an S corporation. The Internal Revenue Service (IRS) (defendant) refused to accept the election, claiming that Savannah had more than 10 shareholders, the maximum number allowed for that kind of election. The remaining Savannah shareholders (plaintiffs) sued the IRS in the United States Tax Court to recover deficiencies resulting from the IRS’s decision to disallow the election.

Rule of Law

Issue

Holding and Reasoning (Raum, J.)

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