Legal Opinion

Lloyd E. Williams, Jr. And Mildred A. Williams v. Commissioner of Internal Revenue

Court of Appeals for the Seventh Circuit

Decided August 31, 1993No. 92-3691PublishedCited by 133 opinions

1Opinion of the Court

POSNER, Circuit Judge.

Section 483 of the Internal Revenue Code, before it was amended in 1984, provided that if the first installment of the price for a purchase was not due for more than six months, the purchaser could pretend that he had borrowed the amount of the installment from the seller and could compute — and when he finally paid the installment, deduct from his taxable income — the portion of the installment that represented'implicit interest on the “loan.” The method of calculating this implicit interest was extremely favorable to the taxpayer. The taxpayers in this case took such…

2Cases cited37 opinions

  1. United States v. National Bank of CommerceSupreme Court of the United States · 1985
  2. Poe v. SeabornSupreme Court of the United States · 1930
  3. Commissioner v. BrownSupreme Court of the United States · 1965
  4. Kenneth W. Martin v. John P. Malhoyt, John Doe(s) Shirley Ann Stevens v. David H. Stover, John DoeCourt of Appeals for the D.C. Circuit · 1987
  5. Lummus Company v. Commonwealth Oil Refining Company, Inc., Lummus Company v. Honorable Archie O. DawsonCourt of Appeals for the Second Circuit · 1962

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3Cited by133 opinions

  1. Alfonso Avitia, and Diane Larsen v. Metropolitan Club of Chicago, Incorporated, Cross-AppelleeCourt of Appeals for the Seventh Circuit · 1995
  2. Michelle Brazinski v. Amoco Petroleum Additives Company and Buck IsbellCourt of Appeals for the Seventh Circuit · 1993
  3. Donald Rehling v. The City of Chicago, a Municipal CorporationCourt of Appeals for the Seventh Circuit · 2000
  4. Rimbert v. Eli Lilly and Co.Court of Appeals for the Tenth Circuit · 2011
  5. Santamarina, Guiller v. Sears RoebuckCourt of Appeals for the Seventh Circuit · 2006

128 more not listed; retrieve them via the Exa API.

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