Legal Opinion
H. C. Franklin and Marjorie Franklin v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided August 16, 1982No. 81-4425PublishedCited by 30 opinions
1Opinion of the Court
ALVIN B. RUBIN, Circuit Judge:
We here consider the deductibility of interest paid by a cash basis taxpayer with money borrowed to fulfill his interest obligations on loans made in participation by a group of banks. The taxpayer borrowed from the lead bank to pay interest due both that bank and the other banks that had participated in loans to him. All parties agree that the portion of the interest payments attributable to the lead bank’s share in the loans is not deductible. Reversing the tax court, we conclude that the portion of the interest payments attributable to the shares of the…
2Cases cited10 opinions
- Helvering v. PriceSupreme Court of the United States · 1940
- Federal Deposit Insurance Corporation v. Mademoiselle Of CaliforniaCourt of Appeals for the Ninth Circuit · 1967
- Barry L. Battelstein and Jerry E. Battelstein v. Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1980
- Crain v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1935
- In Re Fried Furniture Corp.District Court, E.D. New York · 1968
5 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Teachers'retirement System v. La. St. Employees Retirement SystemSupreme Court of Louisiana · 1984
- Hibernia National Bank v. Federal Deposit Insurance CorporationCourt of Appeals for the Tenth Circuit · 1984
- In Re Drexel Burnham Lambert Group Inc.United States Bankruptcy Court, S.D. New York · 1990
- First Bank of WaKeeney v. Peoples State BankCourt of Appeals of Kansas · 1988
- Mason & Dixon Lines, Inc. v. First National Bank of BostonDistrict Court, M.D. North Carolina · 1988
25 more not listed; retrieve them via the Exa API.