Legal Opinion
Estate of Guy L. Mann, Deceased. Suzanne Mann Duval, Administratrix v. United States
Court of Appeals for the Fifth Circuit
Decided May 4, 1984No. 82-1593PublishedCited by 55 opinions
1Opinion of the Court
JOHN R. BROWN, Circuit Judge:
Our case today involves loans between a broker and a businessman — -two brothers, in two businesses related almost as closely. Because of one bankruptcy, and no bucks, the broker loaned the businessman several million dollars. These loans ultimately were the basis of a bad business debt de duction under I.R.C. § 166, and the resulting tax refund under § 172, filed on behalf of the broker. The jury allowed the claim. The Government argues alternatively that the lending brother was merely being “gen-eres,” that he was just protecting his investment, and that the…
2Cases cited35 opinions
- The Boeing Company v. Daniel C. ShipmanCourt of Appeals for the Fifth Circuit · 1969
- Bull v. United StatesSupreme Court of the United States · 1935
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Whipple v. CommissionerSupreme Court of the United States · 1963
- Stone v. WhiteSupreme Court of the United States · 1937
30 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Neeley v. Bankers Trust Co.Court of Appeals for the Fifth Circuit · 1985
- Reading & Bates Corp. v. United StatesUnited States Court of Federal Claims · 1998
- Nch Corporation, Cross-Appellant v. Lynn N. Broyles, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1985
- American Offshore, Inc. v. CommissionerUnited States Tax Court · 1991
- Melvin J. Cole and Harriet L. Cole v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1989
50 more not listed; retrieve them via the Exa API.