Bradford v. Commissioner
United States Tax Court
Petitioner husband was a partner in a securities brokerage business which in the course of that business dealt in tax-exempt securities. It regularly borrowed funds on a daily basis for its various business needs. Held, a portion of such borrowing was for the purpose proscribed by sec. 265 and a deduction therefor is accordingly disallowed. Leslie v. Commissioner, 413 F. 2d 636 (C.A. 2, 1969), reversing 50 T.C. 11 (1968), followed.
1Opinion of the Court
Tannenwald, Judge:
Kespondent determined the following deficiencies in petitioners’ income tax:
Tear Deficiencies
1964 _$6,697.96
1965 _ 6,324.10
1966 _ 5,271.86
The issue for decision is whether, within the meaning of section 265 (2) of the Internal Kevenue Code of 1954, any of the indebtedness of a partnership, doing business as a broker and dealer in securities, was incurred or continued to purchase or carry tax-exempt bonds.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Petitioners James C.…
2Cases cited7 opinions
- United States v. Maryland Savings-Share Ins. Corp.Supreme Court of the United States · 1970
- John E. Leslie and Evelyn G. Leslie v. Commissioner of the Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Leslie v. CommissionerUnited States Tax Court · 1968
- Nammack v. CommissionerUnited States Tax Court · 1971
- Ball v. CommissionerUnited States Tax Court · 1970
2 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- Bayer v. CommissionerUnited States Tax Court · 1992
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- Ellis I. And Nelle S. Levitt, Appellants-Appellees v. United States of America, Appellees-AppellantsCourt of Appeals for the Eighth Circuit · 1975
- Shell Oil Co. v. CommissionerUnited States Tax Court · 1987
- Handy Button Machine Co. v. CommissionerUnited States Tax Court · 1974
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