Legal Opinion

Karns Prime & Fancy Food, Ltd. v. Commissioner

Court of Appeals for the Third Circuit

Decided July 20, 2007No. 06-1031Published

1Opinion of the Court

494 F.3d 404 (2007)

KARNS PRIME & FANCY FOOD, LTD., Appellant

v.

COMMISSIONER OF INTERNAL REVENUE.

No. 06-1031.

United States Court of Appeals, Third Circuit.

Argued March 5, 2007.

Filed: July 20, 2007.

Steven J. Schiffman, John D. Sheridan (Argued), Serratelli, Schiffman, Brown & Calhoun, Harrisburg, PA, for Appellant.

Richard Farber, Bethany B. Hauser (Argued), United States Department of Justice, Washington, DC, for Appellee.

Before: SLOVITER, AMBRO, Circuit Judges, and BRODY,[*] District Judge.

OPINION OF THE COURT

SLOVITER, Circuit Judge.

The distinction between a loan and an advance payment for the…

Also in this document: Concurrence.

2Cases cited15 opinions

  1. Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
  2. Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
  3. Knetsch v. United StatesSupreme Court of the United States · 1960
  4. Commissioner v. TuftsSupreme Court of the United States · 1983
  5. Schulde v. CommissionerSupreme Court of the United States · 1963

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