Legal Opinion
United States v. Snyder Brothers Company
Court of Appeals for the Fifth Circuit
Decided September 27, 1966No. 22111_1PublishedCited by 46 opinions
1Opinion of the Court
TUTTLE, Chief Judge:
We have here for determination the question whether certain twenty-year debentures subordinated to all other indebtedness of the issuing taxpayer corporation constitute an “indebtedness” within the meaning of Section 163 of the Inter*981nal Revenue Code of 1954, 26 U.S.C.A. § 163,1 the interest upon which is allowed as a federal income tax deduction.
The facts are not in dispute. For a number of years Franklin D. Snyder and Floyd R. Snyder were engaged in the business of manufacturing industrial furniture finishes in Toccoa, Georgia, as a lartnership under the name Snyder…
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Dobson v. CommissionerSupreme Court of the United States · 1944
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
9 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Alterman Foods, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Jean C. Tyler and Dolly Ann Tyler v. Laurie W. Tomlinson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
- United States v. Simon W. Henderson, Jr., Independent for the Estate of Louise R. Henderson, DeceasedCourt of Appeals for the Fifth Circuit · 1967
- Laurie W. Tomlinson, District Director of Internal Revenue for the District of Florida v. The 1661 CorporationCourt of Appeals for the Fifth Circuit · 1967
41 more not listed; retrieve them via the Exa API.