Legal Opinion
National-Standard Company v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided December 12, 1984No. 83-1679PublishedCited by 29 opinions
1Opinion of the Court
CONTIE, Circuit Judge.
The Commissioner appeals from a decision of the United States Tax Court in favor of National-Standard Company on National-Standard’s petition for redetermi-nation of a federal income tax deficiency assessed by the Commissioner. We have jurisdiction pursuant to 26 U.S.C. § 7482. We affirm.
I
On September 17, 1970, National-Standard entered into a loan agreement pursuant to which the company borrowed 250,000,000 Luxembourg francs from Caisse E’ Apargne de L’Etat, a Luxembourg bank, between December 31, 1970 and December 20, 1971. The francs had a U.S. dollar value of $5…
2Cases cited32 opinions
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Helvering v. William Flaccus Oak Leather Co.Supreme Court of the United States · 1941
- Bingham v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1939
- Union Planters National Bank of Memphis v. United StatesCourt of Appeals for the Sixth Circuit · 1970
27 more not listed; retrieve them via the Exa API.
3Cited by29 opinions
- Levin v. CommissionerUnited States Tax Court · 1986
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Zarin v. CommissionerUnited States Tax Court · 1989
- Michaels v. CommissionerUnited States Tax Court · 1986
24 more not listed; retrieve them via the Exa API.