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Facts: Petitioners borrowed money from their father and purchased several
lands. For several years, these lands were leased to tenants by the
petitioners. In 1954, respondent Collector of Internal Revenue demanded
from petitioners the payment of income tax on corporations, real estate
dealer's fixed tax and corporation residence tax for the years 1945-1949. A
letter of demand and correspondingassessments were delivered to
petitioners. Petitioners claim that they should be absolved from paying said
taxes since they are not a corporation.
Held: Yes. Petitioners are subject to the income tax and residence tax for
corporation.