Legal Opinion
Texas Farm Bureau v. United States
Court of Appeals for the Fifth Circuit
Decided May 21, 1984No. 82-1355PublishedCited by 23 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
With Congress’ dedicated cultivation, the tax code has prospered and thrived, achieving a rate of growth that tillers of non-legislative soil would be hard-pushed to match. Despite the code’s phenomenal size and detail, courts must still contend with a particularly persistent and pesterous ambiguity. The problem lies not in separating the seed from the chaff, but in telling debt from equity.
Debt-equity questions commonly involve a corporation and its shareholders — the issue being whether monies advanced by the shareholder to the corporation constitute a loan or a…
2Cases cited16 opinions
- Pullman-Standard v. SwintSupreme Court of the United States · 1982
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
- Jean C. Tyler and Dolly Ann Tyler v. Laurie W. Tomlinson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
11 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- American Offshore, Inc. v. CommissionerUnited States Tax Court · 1991
- Central States, Southeast & Southwest Areas Pension Fund v. Creative Development Co.Court of Appeals for the Fifth Circuit · 2000
- Piggy Bank Stations, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1985
- Overnite Transportation Co. v. Commissioner of RevenueMassachusetts Appeals Court · 2002
- DF Systems, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 2013
18 more not listed; retrieve them via the Exa API.