Legal Opinion
Gounares Bros. & Co., Inc. v. United States
Court of Appeals for the Fifth Circuit
Decided June 21, 1961No. 18719_1PublishedCited by 9 opinions
1Opinion of the Court
JOHN R. BROWN, Circuit Judge.
This case presents primarily the question of the accrual of interest as a deduction to the payor corporation on an obligation owing to its controlling stockholder-officer-director. The Commissioner in a deficiency assessment treated the obligation as a debt for which interest would be .payable and deductible. But he concluded that it was accruable during each of the four years and not, as Taxpayer treated it, in the final (fourth) year in which it was paid. Accrual to the prior years had the ostensible and momentary effect of increasing expenses for each of these…
2Cases cited33 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Point Landing, Inc., Intervenor v. Alabama Dry Dock & Shipbuilding CompanyCourt of Appeals for the Fifth Circuit · 1958
- Sun Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Sanders v. LeechCourt of Appeals for the Fifth Circuit · 1946
28 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Putoma Corp., Successor by Merger of Pro-Mac Company, Petitioners- Cross-Appellants v. Commissioner of Internal Revenue, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1979
- Burlington-Rock Island Railroad Company v. United StatesCourt of Appeals for the Fifth Circuit · 1963
- Commissioner of Internal Revenue v. Thompson I. Welch, Individually, Thomspon I. Welch, Individually v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
- Allen Williams B/n/f Louise J. Smyre v. United StatesCourt of Appeals for the Fifth Circuit · 1967
- Tampa & Gulf Coast Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1972
4 more not listed; retrieve them via the Exa API.