Legal Opinion
Rufus C. Salley and Beulah S. Salley v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided July 24, 1972No. 71-3122PublishedCited by 18 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
Taxpayers, Rufus C. Salley and Beulah S. Salley, in search of the ever-elusive grail of the “tax loophole,” appeal from a determination by the Tax Court that so-called interest payments on loans from their controlled insurance company are not deductible under 26 U.S.C.A. §§ 163 (a), 162(a), or 212(1). 1 55 T.C. 896 (1971). We agree with the Tax Court that the alleged loans are without economic substance and do not create a genuine indebtedness between taxpayers and their insurance company that would justify any deductions for so-called interest.
Taxpayers, husband and…
2Cases cited26 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Higgins v. CommissionerSupreme Court of the United States · 1941
- United States v. GilmoreSupreme Court of the United States · 1963
21 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Bail Bonds by Marvin Nelson, Inc., a Corporation v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1987
- Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
- Compaq Computer Corporation & Subsidiaries v. CommissionerCourt of Appeals for the Fifth Circuit · 2001
- Barry L. Battelstein and Jerry E. Battelstein v. Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1980
- Minnis v. CommissionerUnited States Tax Court · 1979
13 more not listed; retrieve them via the Exa API.