Earl Drown Corp. v. Commissioner
United States Tax Court
Petitioners were the general partners of DNA, which was a wholesale distributor of magazines and paperback books of various publishers. DNA annually would borrow money from DPI and the Drown Trust to help fund December payments to publishers. During the years in issue, DNA purchased tax-exempt bonds from excess funds generated from its business.
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Petitioners were the general partners of DNA, which was a wholesale distributor of magazines and paperback books of various publishers. DNA annually would borrow money from DPI and the Drown Trust to help fund December payments to publishers. During the years in issue, DNA purchased tax-exempt bonds from excess funds generated from its business. At the time of such purchases, DNA reasonably could have foreseen that a loan probably would be necessary to satisfy its future economic needs, which were of an ordinary, recurrent nature. Held, the interest expense deducted by DNA for interest paid…
1Opinion of the Court
Earl Drown Corporation, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Earl Drown Corp. v. Commissioner
Docket Nos. 3350-82, 3351-82, 3352-82
United States Tax Court
86 T.C. 217; 1986 U.S. Tax Ct. LEXIS 151; 86 T.C. No. 15;
February 24, 1986, Filed
Decisions will be entered under Rule 155.
Petitioners were the general partners of DNA, which was a wholesale distributor of magazines and paperback books of various publishers. DNA annually would borrow money from DPI and the Drown Trust to help fund December payments to publishers. During the years in issue, DNA purchased…
2Cases cited16 opinions
- Denman v. SlaytonSupreme Court of the United States · 1931
- The Wisconsin Cheeseman, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1968
- John E. Leslie and Evelyn G. Leslie v. Commissioner of the Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Illinois Terminal Railroad Company v. The United StatesUnited States Court of Claims · 1967
- Leslie v. CommissionerUnited States Tax Court · 1968
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