Legal Opinion
Scriptomatic, Inc. v. United States
Court of Appeals for the Third Circuit
Decided May 13, 1977No. 75-2078, 76-1732PublishedCited by 32 opinions
1Opinion of the Court
OPINION OF THE COURT
VAN DUSEN, Circuit Judge.
The question in this case is whether payments made on two series 1 of obligations (denominated “debentures”) of Scriptomatic, Inc. (plaintiff) were deductible as interest under 26 U.S.C. § 163, or were, in reality, disguised dividends and therefore not deductible by the corporation. On June 24, 1975, the district court entered judgment for plaintiff notwithstanding a December 1973 jury verdict answering special questions in favor of defendant, 2 see Scripto-matic Inc. v. United States, 397 F.Supp. 753 (E.D.Pa.1975), from which the government…
2Cases cited5 opinions
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- P. M. Finance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Scriptomatic, Inc. v. United StatesDistrict Court, E.D. Pennsylvania · 1975
- Universal Castings Corporation, an Illinois Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- In re ZeidlerDistrict Court, E.D. New York · 1975
3Cited by32 opinions
- Herbert A. Dunn and Georgia E. Dunn v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1980
- Segel v. CommissionerUnited States Tax Court · 1987
- Jonathan B. Geftman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1998
- Indmar Products Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- CMA Consol., Inc. v. Comm'rUnited States Tax Court · 2005
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