Legal Opinion
Alterman Foods, Inc. v. United States
Court of Appeals for the Fifth Circuit
Decided January 13, 1975No. 73-3852PublishedCited by 92 opinions
1Opinion of the Court
TUTTLE, Circuit Judge:
This tax case involves a dispute over the legal effects of cash advances made to a parent corporation Dy a number of its wholly-owned subsidiaries, shown on the books of both the subsidiaries and parent as debts outstanding, but on which there were no interest charges, no set maturity date, no notes of indebtedness, nor any apparent legal compulsion to repay the amounts outstanding. No effort was ever made to force repayment on the part of any of the subsidiaries involved.
The Internal Revenue Service assessed a deficiency of $113,882.72 with interest of $18,193.78 on the…
2Cases cited27 opinions
- The Boeing Company v. Daniel C. ShipmanCourt of Appeals for the Fifth Circuit · 1969
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Gene O. Clark and Faye Clark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
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3Cited by92 opinions
- Dixie Dairies Corp. v. CommissionerUnited States Tax Court · 1980
- West v. WestMississippi Supreme Court · 2004
- Dolese v. United StatesCourt of Appeals for the Tenth Circuit · 1979
- Ralph D. Crowley and Frances A. Crowley v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1992
- Richard E. Busch Jr. & Jean N. Busch v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
87 more not listed; retrieve them via the Exa API.