Legal Opinion

Wilshire & West. Sandwiches v. Commissioner of Int. R.

Court of Appeals for the Ninth Circuit

Decided June 23, 1949No. 12079PublishedCited by 55 opinions

1Opinion of the Court

ORR, Circuit Judge.

In its income tax returns for the years 1942 and 1943 petitioner deducted from its gross income sums claimed by it to have been paid as interest on an indebtedness evidenced by notes executed by it. The authority to make the deduction was claimed under § 23(b) of the Internal Revenue Code. 1 The Commissioner of Internal Revenue disallowed the deductions and determined deficiencies. Petitioner asked for a redetermination by the Tax Court. That court sustained the Commissioner. We have for review the Tax Court’s decision.

The question presented is: Were certain advances of…

2Cases cited2 opinions

  1. Commissioner of Int. Rev. v. Meridian & Thirteenth R. Co.Court of Appeals for the Seventh Circuit · 1942
  2. Maloney v. SpencerCourt of Appeals for the Ninth Circuit · 1949

3Cited by55 opinions

  1. John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
  2. Litton Business Systems, Inc. v. CommissionerUnited States Tax Court · 1973
  3. A. R. Lantz Co., Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1970
  4. Gooding Amusement Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1956
  5. Matthiessen v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952

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