Negative Easement Payments Found to Be Rental Income for Personal Holding Tax Purposes

Is paying a C corporation not to make use of property rental income?  The question arises in this case in order to determine if such payments potentially constitute personal holding company income under IRC §543 which could end up subjecting the corporation to the personal holding company tax under IRC §541 if it is determined to be a personal holding company pursuant to IRC §542.  Field Service Advice 20152102F attempts to answer this question.

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