Legal Opinion
Charles H. & Lessie B. Davison v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided March 18, 1998No. Docket 97-4008PublishedCited by 4 opinions
1Per curiam
Charles H. and Lessie B. Davison appeal from the judgment of the United States Tax Court (Robert P. Ruwe, Judge), denying their petition for redetermination of deficiencies determined by the Commissioner of Internal Revenue for the 1977 and 1980 tax years. The Tax Court upheld the Commissioner’s disallowance of the Davisons’ deduction of their allocable share of an interest payment made by a general partnership in which Charles H. Davison was a partner. Because the interest payment was made using funds borrowed from the same lender to whom the interest was owed, for the purpose of making that…
2Cases cited7 opinions
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- G. Douglas Burck and Marjorie W. Burck v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Burgess v. CommissionerUnited States Tax Court · 1947
- Barry L. Battelstein and Jerry E. Battelstein v. Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1980
- Wilkerson v. CommissionerCourt of Appeals for the Ninth Circuit · 1981
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3Cited by4 opinions
- Sumitomo Mitsui Banking Corp. v. Credit SuisseAppellate Division of the Supreme Court of the State of New York · 2011
- Charles Mellor Hargreaves & Karima Hargreaves v. CommissionerUnited States Tax Court · 2013
- Damer v. Comm'rUnited States Tax Court · 2009
- George Russell Reiff, Jr. & Amy Reiff v. CommissionerUnited States Tax Court · 2013