Hirotoshi Yamamoto v. Commissioner
United States Tax Court
Petitioner husband (H) was sole owner of the voting stock of MFC, an industrial loan company in Hawaii. Hawaii requires industrial loan companies to maintain a debt-to-capital ratio of ten-to-one. In years before the years in issue, H borrowed money and used the loan proceeds to buy more stock in MFC. In Yamamoto v. Commissioner, T.C.
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Petitioner husband (H) was sole owner of the voting stock of MFC, an industrial loan company in Hawaii. Hawaii requires industrial loan companies to maintain a debt-to-capital ratio of ten-to-one. In years before the years in issue, H borrowed money and used the loan proceeds to buy more stock in MFC. In Yamamoto v. Commissioner, T.C. Memo. 1986-316, affd. without published opinion 891 F.2d 297 (CA9 1989), we held that deduction of H's interest payments on those loans was limited by the investment interest rules. H incorporated MEI, a holding company, on June 20, 1977. On June 28, 1977, in…
1Opinion of the Court
HIROTOSHI YAMAMOTO AND SHIZUKO YAMAMOTO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hirotoshi Yamamoto v. Commissioner
Docket No. 13280-85
United States Tax Court
T.C. Memo 1990-549; 1990 Tax Ct. Memo LEXIS 621; 60 T.C.M. (CCH) 1050; T.C.M. (RIA) 90549;
October 23, 1990, Filed
Decision will be entered under Rule 155.
Petitioner husband (H) was sole owner of the voting stock of MFC, an industrial loan company in Hawaii. Hawaii requires industrial loan companies to maintain a debt-to-capital ratio of ten-to-one. In years before the years in issue, H borrowed money and used the loan…
2Cases cited44 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Montana v. United StatesSupreme Court of the United States · 1979
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. TaylorSupreme Court of the United States · 1935
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