Capital Inv. of Hawaii, Inc. v. Commissioner
United States Tax Court
Petitioner, an accrual basis taxpayer, guaranteed a 9-1/4 percent yield to "transferees" of participating interests in notes. Held, petitioner's obligation is one to pay interest. Held further, when principal may be prepaid, the passage of time is necessary before an accrual basis taxpayer may deduct an obligation to pay interest.
1Opinion of the Court
CAPITAL INVESTMENT OF HAWAII, INCORPORATED AND AFFILIATES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Capital Inv. of Hawaii, Inc. v. Commissioner
Docket No. 3346-79.
United States Tax Court
T.C. Memo 1982-80; 1982 Tax Ct. Memo LEXIS 665; 43 T.C.M. (CCH) 572; T.C.M. (RIA) 82080;
February 17, 1982.
Petitioner, an accrual basis taxpayer, guaranteed a 9-1/4 percent yield to "transferees" of participating interests in notes. Held, petitioner's obligation is one to pay interest. Held further, when principal may be prepaid, the passage of time is necessary before an accrual basis taxpayer…
2Cases cited13 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higginbotham-Bailey-Logan Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- World Airways, Inc. v. CommissionerUnited States Tax Court · 1974
- World Airways, Inc., and World Air Center, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1977
- Gunderson Bros. Engineering Corp. v. CommissionerUnited States Tax Court · 1964
8 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- National Life Insurance Company and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996