McLane v. Commissioner
United States Tax Court
1. Held, legislative history of statutory prohibition against deduction of interest on loans to purchase multiple-premium annuities does not allow a deduction arising from transaction occurring prior to effective date of such legislation, where the transaction lacks economic substance. 2. Held, further, there was no unjust discrimination arising from petitioner's alleged reliance on earlier rulings issued to others by respondent and public statements by respondent.
1Opinion of the Court
Tannenwald, Judge:
Respondent determined deficiencies in the 1958 Federal income tax of petitioner W. Lee McLane, Jr., of $10,073.19 and in the 1958 Federal income tax of petitioner Rola McLane of $10,075.86. The cases were consolidated for trial. The only issue for decision is whether certain amounts paid during 1958 are deductible as interest.
FINDINGS OF FACT
Some facts are stipulated and are found accordingly.
Petitioners were husband and wife and resided in Phoenix, Ariz., during the year in issue. Their Federal income tax returns were prepared on the cash method of accounting and timely…
2Cases cited16 opinions
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Commissioner v. BrownSupreme Court of the United States · 1965
- Rock Island, Arkansas & Louisiana Railroad v. United StatesSupreme Court of the United States · 1920
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- International Business MacHines Corporation v. The United StatesUnited States Court of Claims · 1965
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3Cited by34 opinions
- Lemmen v. CommissionerUnited States Tax Court · 1981
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
- Hager v. CommissionerUnited States Tax Court · 1981
- Golsen v. CommissionerUnited States Tax Court · 1970
- Winn-Dixie Stores v. Comm'rUnited States Tax Court · 1999
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