Legal Opinion
First National Company v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided April 28, 1961No. 14059PublishedCited by 21 opinions
1Opinion of the Court
SHACKELFORD MILLER, Jr., Circuit Judge.
The Commissioner of Internal Revenue determined an income tax deficiency against the petitioner, First National Company, for the taxable years 1951, 1952 and 1953 in the respective amounts of $42,381.19, $5,742.79 and $6,597.97. The deficiency was based upon the dis-allowance by the Commissioner of deductions taken by the petitioner as interest paid by it during the years in question on its outstanding promissory note in the principal amount of $1,838,299.10, the Commissioner holding that the note did not represent any genuine and then existing…
2Cases cited15 opinions
- Securities & Exchange Commission v. Chenery Corp.Supreme Court of the United States · 1943
- Helvering v. GowranSupreme Court of the United States · 1937
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- Autenreith v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1940
- Seagrave Corp. v. Mount Spain v. MountCourt of Appeals for the Sixth Circuit · 1954
10 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Jordan v. CommissionerUnited States Tax Court · 1973
- Union Planters Nat. Bank of Memphis v. MarkowitzDistrict Court, W.D. Tennessee · 1979
- Tmf Tool Company, Incorporated and Anton Kastory v. Robert C. Siebengartner and R.C. Siebengartner IncorporatedCourt of Appeals for the Seventh Circuit · 1990
- Perkins v. CommissionerUnited States Tax Court · 1989
- Hubert Enters. v. Comm'rUnited States Tax Court · 2005
16 more not listed; retrieve them via the Exa API.