Rountree Cotton Co. v. Commissioner

113 T.C. No. 28

UNITED STATES TAX COURT ROUNTREE COTTON CO., INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24014-97. Filed December 16, 1999. R determined that C made below-market-interest loans directly and indirectly to C’s shareholders within the meaning of sec. 7872, I.R.C. The “indirect” loans were to entities owned in part by C’s shareholders. C contends that sec. 7872, I.R.C., was not intended to apply to a loan by C to a shareholder of C who does not have a majority or controlling interest in C. C also contends that sec. 7872, I.R.C., does not apply to a…