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Service Bolt & Nut Co. v. Commissioner
United States Tax Court
78 T.C. 812 (1982)
- Written by Sean Carroll, JD
Facts
Service Bolt & Nut Company (the trust) (plaintiff) was a profit-sharing trust that held a limited-partnership interest in several fastener-distribution partnerships. The trust was a tax-exempt organization. The Internal Revenue Service (IRS) (defendant) determined that any income that the trust received from the partnership interest was unrelated business taxable income, taxable upon the trust. The trust appealed in the United States Tax Court, arguing that as a passive investor, a tax-exempt organization’s limited-partnership interest could not produce unrelated business taxable income.
Rule of Law
Issue
Holding and Reasoning (Nims, J.)
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