Legal Opinion

Hypotheek Land Co. v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided December 15, 1952No. 13158_1PublishedCited by 14 opinions

1Opinion of the Court

BONE, Circuit Judge.

The basic and material facts underlying the controlling issues presented in this review proceeding are clearly set forth in the opinion and findings of the Tax Court reported in 16 T.C. 126.8. A detailed summary of these facts is therefore unnecessary.

In its opinion the Tax Court states that “the sole issue is whether the • respondent [Commissioner] erred in reducing petitioner’s deduction of interest allowable on its obligation to the [two so-called] Dutch banks from the rate of 5 per cent to 3 per cent.” In disallowing the deduction for interest in excess of 3 per cent…

2Cases cited8 opinions

  1. Helvering v. RankinSupreme Court of the United States · 1935
  2. Lucas v. Ox Fibre Brush Co.Supreme Court of the United States · 1930
  3. Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
  4. Gillette's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1950
  5. McCullough v. Kammerer CorporationCourt of Appeals for the Ninth Circuit · 1948

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

3Cited by14 opinions

  1. Stockton Harbor Industrial Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1954
  2. Harold Wener v. Commissioner of Internal Revenue, Molly Wener v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
  3. Suzy's Zoo (R) v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
  4. Hawaiian Trust Company Limited v. United StatesCourt of Appeals for the Ninth Circuit · 1961
  5. Chicago & N. W. R. Co. v. CommissionerUnited States Tax Court · 1958

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

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