Gibson Products Co. Kell Blvd. v. United States

REAVLEY, Circuit Judge:

This is a taxpayer’s refund suit under 28 U.S.C. § 1346(1). Gibson Products Company, an accrual basis taxpayer, appeals from a judgment denying it recovery of $25,-414.48 in taxes and interest which it alleges were erroneously assessed and collected by the Government for the 1972 tax year. Gibson Products contends that the district court erred in sustaining the disallowance by the Commissioner of Internal Revenue for the deduction, as an intangible drilling expense in 1972, of taxpayer’s pro rata share of liability on a nonrecourse note given in that year by a limited…