Mississippi Chemical Corporation v. United States of America, Coastal Chemical Corporation v. United States

GEWIN, Circuit Judge:

The government appeals from separate judgments entered for Mississippi Chemical Corporation and Coastal Chemical Corporation (hereinafter, taxpayers) in their suits for refund of federal taxes. Taxpayers based their claims for refund on the contention that $99 of each $100 expended for the purchase of certain Class C stock in the New Orleans Bank for Cooperatives constituted deductible expenses in the year of purchase. The government contended that these amounts were the nondeduetible costs of acquiring capital assets. The district court concluded that the payments were…