Legal Opinion
Imperial Car Distributors, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided June 23, 1970No. Nos. 18083-18085PublishedCited by 2 opinions
1Opinion of the Court
*1335OPINION OF THE COURT
ALDISERT, Circuit Judge.
Appellants here are the corporate taxpayer, Imperial Car Distributors, Inc., and its stockholder-taxpayers, Frederic and Toby Royston. At issue is the tax treatment of monies received by the Roystons as noteholders from Imperial. Appellants contend that these payments were in satisfaction of corporate indebtedness and thus reportable as capital gains to the noteholders under Section 1232(a) (1) of the Internal Revenue Code of 1954. The corporation seeks the corollary right of interest deductions from the amount of interest paid on the notes.…
2Cases cited7 opinions
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Walter H. Kaltreider and Irene C. Kaltreider v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- P. M. Finance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Cuyuna Realty Company v. The United StatesUnited States Court of Claims · 1967
- Jewell Ridge Coal Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Thomas H. Hutton and Betty Hutton v. United StatesCourt of Appeals for the Sixth Circuit · 1974
- Imperial Car Distributors, Inc. v. Commissioner of Internal Revenue. Frederic Royston and Toby L. Royston v. Commissioner of Internal Revenue. Imperial Car Distributors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1970