Legal Opinion
R. C. Owen Company v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided October 7, 1965No. 16018PublishedCited by 7 opinions
1Opinion of the Court
O’SULLIVAN, Circuit Judge.
Petitioner, R. C. Owen Company, a Kentucky Corporation, seeks reversal of a decision of the Tax Court, which sustained the Commissioner of Internal Revenue’s disallowance of deductions for interest paid by petitioner in the years 1954, 1955 and 1956 upon its issue of so-called debenture bonds. The Tax Court after making its Findings of Fact and expressing its view of applicable law, concluded as follows:
“Under all the circumstances, we are persuaded that petitioner’s Debenture Bonds do not represent a bona fide indebtedness and we therefore hold that respondent…
2Cases cited10 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Towanda Textiles, Inc. v. United StatesUnited States Court of Claims · 1960
- Foresun, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- John R. Carkhuff Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1970
- Fellinger v. United StatesCourt of Appeals for the Sixth Circuit · 1966
- Hayutin v. CommissionerUnited States Tax Court · 1972
- Ragland Investment Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1970
- Herold Fellinger and Clara Fellinger v. United States of America, Maurice Bernstein and Irene Bernstein v. United States of America, the Hippodrome Building Co. v. Commissioner of Internal Revenue, Edwin I. Bamberger and Rita Bamberger v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1966
2 more not listed; retrieve them via the Exa API.