Legal Opinion
In Re James A. Lane, Bankrupt. Frances B. Lane and James M. Gaines, as Trustee of the Bankrupt Estate of James A. Lane v. United States
Court of Appeals for the Eleventh Circuit
Decided September 27, 1984No. 83-7451PublishedCited by 64 opinions
1Opinion of the Court
HATCHETT, Circuit Judge:
In this tax refund case, we decide that advances from a shareholder-taxpayer to several corporations did not constitute debt, deductible under 26 U.S.C.A. § 166 (West 1978). We affirm.
Background
James A. Lane, the taxpayer, is involved in the real estate business. In 1961, Lane acquired the Parliament House property in Birmingham, Alabama, and operated it as a hotel until March, 1972. In 1972, Lane sold the hotel netting approximately $1 million. Due to this large amount of income, Lane paid taxes of over $321,000.
Following sale of the Parliament House, Lane became…
2Cases cited16 opinions
- Putnam v. CommissionerSupreme Court of the United States · 1956
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Byerlite Corporation v. Parker C. Williams, District Director of Internal Revenue, Eighteenth District of OhioCourt of Appeals for the Sixth Circuit · 1960
- Jean C. Tyler and Dolly Ann Tyler v. Laurie W. Tomlinson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
- Merritt-Chapman & Scott Corp. v. United StatesSupreme Court of the United States · 1967
11 more not listed; retrieve them via the Exa API.
3Cited by64 opinions
- Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- Estate of Leavitt v. CommissionerUnited States Tax Court · 1988
- Edward M. Selfe and Jane B. Selfe v. United StatesCourt of Appeals for the Eleventh Circuit · 1985
- In Re Cold Harbor Associates, L.P.United States Bankruptcy Court, E.D. Virginia · 1997
- Hillsborough Holdings Corp. v. Celotex Corp. (In Re Hillsborough Holdings Corp.)United States Bankruptcy Court, M.D. Florida · 1994
59 more not listed; retrieve them via the Exa API.