Legal Opinion
Tulia Feedlot, Inc. v. United States
Court of Appeals for the Fifth Circuit
Decided June 2, 1975No. 74-1928PublishedCited by 50 opinions
1Opinion of the Court
WISDOM, Circuit Judge:
Tulia Feedlot, a closely-held Texas business corporation, brought this tax refund suit to recover income taxes and interest totalling $23,798.81, which it paid under protest when the Commissioner of Internal Revenue disallowed its deduction of $54,000 for alleged guarantors’ fees that it had paid, pro rata, to its director-shareholders during its tax year ending August 31, 1970. The question this case presents is whether the taxpayer may deduct as ordinary and necessary business expenses amounts paid its shareholders ostensibly as guarantors’ fees. The district court,…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Armour & Co. v. WantockSupreme Court of the United States · 1944
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Commissioner v. TellierSupreme Court of the United States · 1966
15 more not listed; retrieve them via the Exa API.
3Cited by50 opinions
- J. W. Durrett, Sr. v. The Washington National Insurance Co.Court of Appeals for the Fifth Circuit · 1980
- Bennie Whitehead v. Food Max of Mississippi, Inc., Kmart Corporation v. Paul S. MinorCourt of Appeals for the Fifth Circuit · 2003
- Sealed v. SealedCourt of Appeals for the Fifth Circuit · 2004
- Owensby & Kritikos, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1987
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
45 more not listed; retrieve them via the Exa API.