"Bob" <bob[at]nospam.com> wrote:

- quote -

No, it does not imply that. Interest received by a closely
held corporation is generally personal holding company
income, Tax Code Sec. 543(a)(1). A separate rule [Sec.
542(c)(6)] says that a lending/finance company is not a
personal holding company if it meets certain ratio tests as
to sources of income and types of deductions.

Bob Daniels ("The Tax Code -- software written by lawyers.")

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

Interest received by a natural person who is in the business
of lending money and buying/selling mortgages is not
portfolio income, it is self-employment income. Does that
imply that such interest, when received by a C corporation
in the same line of business, is not personal holding
company income?


<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >