Legal Opinion
Howard I. Lukens v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided October 7, 1991No. 91-4027PublishedCited by 51 opinions
1Opinion of the Court
KING, Circuit Judge:
Taxpayer Howard I. Lukens appeals from a ruling by the tax court disallowing interest deductions based on its finding that Lukens’ investment in timeshare units did not constitute genuine indebtedness. Lukens’ contentions with regard to this finding focus on the tax court’s method of valuation of the property. Lukens also contests the tax court’s ruling that he is liable for penalty interest payments under 26 U.S.C. § 6621(c) because his tax deficiency was a substantial underpayment attributable to the timeshare purchase transaction. Finding no error in the judgment of the…
2Cases cited27 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
22 more not listed; retrieve them via the Exa API.
3Cited by51 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- August C. Wolf Muriel M. Wolf v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Seymour Sacks Star Sacks v. Commissioner, Internal Revenue Service, Michael R. Geyser Joyce Geyser v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- ESTATE OF DAVIS v. COMMISSIONERUnited States Tax Court · 1998
46 more not listed; retrieve them via the Exa API.