Legal Opinion
Head Ski Company, Inc. v. United States
Court of Appeals for the Fourth Circuit
Decided January 26, 1972No. 71-1544PublishedCited by 7 opinions
1Per curiam
The government appeals from the entry of summary judgment in favor of Head Ski Company granting a refund of income tax for 1965. 1
The sole issue is whether a premium Head Ski paid for the redemption of a convertible note was deductible as a business expense or nondeductible as a capital outlay. Applying Treasury Regulation § 1.61-12(e) (1) (1965), 2 the district court held that the premium was deductible. In reaching this conclusion, it relied primarily on Southwest Grease & Oil Company, Inc. v. United States, 435 F.2d 675 (10th Cir. 1971), and Roberts & Porter, Inc. v. Commissioner of…
2Cases cited2 opinions
- Roberts & Porter, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- Southwest Grease & Oil Co., Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1971
3Cited by7 opinions
- Hunt Foods & Industries, Inc. v. CommissionerUnited States Tax Court · 1972
- National Can Corp. v. United StatesDistrict Court, N.D. Illinois · 1981
- Richmond, F. & P. R. Co. v. CommissionerUnited States Tax Court · 1974
- Richmond, Fredericksburg and Potomac Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1975
- Hunt Foods & Industries, Inc. v. CommissionerUnited States Tax Court · 1972
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