Legal Opinion
Allen v. United States
District Court, E.D. North Carolina
Decided December 2, 1997No. 5:96-cv-00909PublishedCited by 5 opinions
1Opinion of the Court
ORDER
JAMES C. FOX, Chief Judge.
In this action, the plaintiff Richard R. Allen (“Allen”), a cash basis taxpayer, seeks a refund of federal income tax paid for the year 1992. The sole issue in this case is whether Allen may deduct deficiency interest paid in 1992 when the deficiency interest arose from adjustments made by the Internal Revenue Service (“IRS”) to items of income generated by Allen’s real estate business activities.
I. Findings of Fact
The facts of this case are not disputed by the parties. In the years preceding 1984, Richard Allen was engaged in the business of purchasing,…
2Cases cited19 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- MCI Telecommunications Corp. v. American Telephone & Telegraph Co.Supreme Court of the United States · 1994
14 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Richard R. Allen, Sr., a Resident of Fayetteville, Nc v. United States of America, Acting by and Through the Internal RevenueCourt of Appeals for the Fourth Circuit · 1999
- Allen v. United StatesCourt of Appeals for the Fourth Circuit · 1999
- Edward A. Robinson III and Diana R. Robinson v. CommissionerUnited States Tax Court · 2002
- Robinson v. Comm'rUnited States Tax Court · 2002
- Robinson v. Comm'rUnited States Tax Court · 2002