Legal Opinion
Fin Hay Realty Co. v. United States
Court of Appeals for the Third Circuit
Decided June 20, 1968No. 16582PublishedCited by 190 opinions
1Opinion of the Court
OPINION OF THE COURT
FREEDMAN, Circuit Judge.
We are presented in this case with the recurrent problem whether funds paid to *695a close corporation by its shareholders were additional contributions to capital or loans on which the corporation’s payment of interest was deductible under § 163 of the Internal Revenue Code of 1954.1
The problem necessarily calls for an evaluation of the facts, which we therefore detail.
Fin Hay Realty Co., the taxpayer, was organized on February 14, 1934,2 by Frank L. Finlaw and J. Louis Hay. Each of them contributed $10,000 for which he received one-half of the…
2Cases cited9 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
- United States v. Simon W. Henderson, Jr., Independent for the Estate of Louise R. Henderson, DeceasedCourt of Appeals for the Fifth Circuit · 1967
- Laurie W. Tomlinson, District Director of Internal Revenue for the District of Florida v. The 1661 CorporationCourt of Appeals for the Fifth Circuit · 1967
- P. M. Finance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
4 more not listed; retrieve them via the Exa API.
3Cited by190 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Recklitis v. CommissionerUnited States Tax Court · 1988
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Dixie Dairies Corp. v. CommissionerUnited States Tax Court · 1980
- Alterman Foods, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
185 more not listed; retrieve them via the Exa API.