MacRae v. Commissioner
United States Tax Court
Held, on the facts, petitioners did not purchase various amounts of United States Treasury notes and Land Bank bonds, did not borrow large sums of money, and did not pay any amount deductible as interest.
1Opinion of the Court
FoeResteR, Judge:
Respondent has determined deficiencies and an addition in the income tax of petitioners for the calendar years 1952 and 1953 as follows:
Addition
Tear Deficiency See. S9i(d)(2)
1952 _$23, 998. 38 -
1953 _ 109,768.42 $6,172.19
Petitioners raise no separate contentions with respect to the addition for 1953; consequently, the sole issue remaining is the deductibility of certain purported interest payments.
FINDINGS OF FACT.
The stipulated facts are so found.
At all times material petitioners have been husband and wife residing in Beverly Hills, California. Their joint income tax returns…
2Cases cited10 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1959
- Goodstein v. CommissionerUnited States Tax Court · 1958
- Emmons v. CommissionerUnited States Tax Court · 1958
5 more not listed; retrieve them via the Exa API.
3Cited by54 opinions
- Karme v. CommissionerUnited States Tax Court · 1980
- Albert Gordon MacRae and Sheila MacRae v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- Bridges v. CommissionerUnited States Tax Court · 1963
- Golsen v. CommissionerUnited States Tax Court · 1970
- Maxwell Rubin v. United StatesCourt of Appeals for the Seventh Circuit · 1962
49 more not listed; retrieve them via the Exa API.