Legal Opinion
Sidney B. Lifschultz and Charlotte Lifschultz v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided April 15, 1968No. 31590_1PublishedCited by 13 opinions
1Opinion of the Court
HAYS, Circuit Judge:
Sidney B. Lifschultz, 1 petitions this court for review of a decision of the Tax Court upholding the Commissioner’s assessment of deficiencies in income tax payments for the years 1955 and 1956. We deny the petition and affirm the Tax Court.
The deficiencies in question result from the disallowance of certain deductions which taxpayer claims represent the payment of interest on loans. Respondent denies that the payments constituted interest within the meaning of Section 163(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 163(a). 2
The facts are not in dispute. 3 On…
2Cases cited4 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Maxwell Rubin v. United StatesCourt of Appeals for the Seventh Circuit · 1962
3Cited by13 opinions
- United States v. Victor Wexler, Honorable John W. Bissell, NominalCourt of Appeals for the Third Circuit · 1994
- Rothschild v. United StatesUnited States Court of Claims · 1969
- Alfred D. Goldman v. United StatesCourt of Appeals for the Tenth Circuit · 1968
- Sumner E. And Barbara P. Brown v. The United StatesUnited States Court of Claims · 1968
- Rothschild v. United StatesUnited States Court of Claims · 1969
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