Legal Opinion
Azar Nut Company v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided May 15, 1991No. 90-4462PublishedCited by 13 opinions
1Opinion of the Court
W. EUGENE DAVIS, Circuit Judge:
Azar Nut Company (“Azar”) incurred a loss when it sold a house purchased from an employee pursuant to an employment contract. The Tax Court rejected Azar’s attempt to deduct the loss as an ordinary loss under I.R.C. § 165 or as an ordinary and necessary business expense under I.R.C. § 162. We affirm.
I
Azar is in the business of processing, packaging, and marketing nuts in El Paso, Texas. As owners Edward and Phillip Azar approached retirement age, they decided to gradually lessen their management participation in Azar. After a nationwide search for a high level…
2Cases cited10 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Arkansas Best Corp. v. CommissionerSupreme Court of the United States · 1988
- Carter-Colton Cigar Co. v. CommissionerUnited States Tax Court · 1947
- Dresser Industries, Inc. And Consolidated Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
5 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Andrew Crispo Gallery, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1994
- Circle K Corp. v. United StatesUnited States Court of Claims · 1991
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Guardian Indus. Corp. v. CommissionerUnited States Tax Court · 1991
- CMA Consol., Inc. v. Comm'rUnited States Tax Court · 2005
8 more not listed; retrieve them via the Exa API.