Legal Opinion
Estate of Travis Mixon, Jr. v. United States
Court of Appeals for the Fifth Circuit
Decided July 5, 1972No. 71-2666PublishedCited by 133 opinions
1Opinion of the Court
THORNBERRY, Circuit Judge:
The frequently litigated issue of whether funds supplied to a business are, in substance, debt or equity and consequently whether reimbursement is to be considered for federal income tax purposes as a loan repayment or a dividend distribution arises once again in the instant case. 1 The instant appeal involves federal income taxes, penalties, and interest for the year 1963 in the amount of $126,964.54. After an assessment in this amount was paid in full by the taxpayer, he filed a claim for refund which was disallowed by the Commissioner. On December 18, 1969,…
2Cases cited35 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
30 more not listed; retrieve them via the Exa API.
3Cited by133 opinions
- Recklitis v. CommissionerUnited States Tax Court · 1988
- Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1986
- Dixie Dairies Corp. v. CommissionerUnited States Tax Court · 1980
- Alterman Foods, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Segel v. CommissionerUnited States Tax Court · 1987
128 more not listed; retrieve them via the Exa API.