Llewellyn v. Commissioner
United States Tax Court
Held, interest expense cannot be netted against interest income to determine gross receipts from interest within the meaning of sec. 1372(e)(5)(B), I.R.C. 1954.
1Opinion of the Court
Morgan Llewellyn and Mattie Llewellyn, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Llewellyn v. Commissioner
Docket Nos. 10291-75, 10297-75, 10298-75
United States Tax Court
70 T.C. 370; 1978 U.S. Tax Ct. LEXIS 111;
May 30, 1978, Filed
Held, interest expense cannot be netted against interest income to determine gross receipts from interest within the meaning of sec. 1372(e)(5)(B), I.R.C. 1954.
Robert B. St. Peters and John W. Hoefert, for the petitioners.
James F. Kidd, for the respondent.
Wiles, Judge.
WILES
OPINION
On October 3, 1977, respondent filed a motion for summary…
2Cases cited1 opinion
- Llewellyn v. CommissionerUnited States Tax Court · 1978