Goldstein v. Commissioner
United States Tax Court
Held, that sums which petitioner Tillie Goldstein paid, purportedly as "prepaid interest" on two newly created items of "indebtedness," did not in substance and reality constitute "interest * * * on indebtedness," within the intendment of section 163(a), I.R.C. 1954; and accordingly said sums are not deductible.
1Opinion of the Court
Pierce, Judge:
On October 20, 1964, this Court filed in this case Memorandum Findings of Fact and Opinion, and also entered a decision in accordance therewith.
Thereafter on November 19, 1964, the petitioners filed herein motions for reconsideration of said Memorandum Findings of Fact and Opinion, and also for revision of said decision. The Court, upon consideration thereof, entered an order herein on November 23, 1964, wherein it was ordered: (1) That the said decision entered in this case on October 20,1964, be, and the same was, withdrawn and vacated; (2) that petitioners’ motion for…
2Cases cited8 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Joseph H. Bridges and Lillier J. Bridges v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
3 more not listed; retrieve them via the Exa API.
3Cited by112 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Enoch v. CommissionerUnited States Tax Court · 1972
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Sandor v. CommissionerUnited States Tax Court · 1974
- Hulter v. CommissionerUnited States Tax Court · 1988
107 more not listed; retrieve them via the Exa API.