Legal Opinion
Mason v. United States
District Court, N.D. California
Decided July 13, 1978No. C-77-1517-CBRPublishedCited by 4 opinions
1Opinion of the Court
MEMORANDUM OF OPINION
RENFREW, District Judge.
Plaintiffs seek a refund of a deficiency assessment of their 1968 taxes as a result of the disallowance of a deduction for interest payments. Their claim is based upon the theory that the Internal Revenue Service (IRS) should allow a deduction from gross income, pursuant to Internal Revenue Code § 163, 26 U.S.C. § 163, 1 based on a proportion of total interest paid by plaintiff Raymond Mason and his partner on a judgment for which both were liable, regardless of how the payments were characterized by the creditor. The United States has moved for…
2Cases cited23 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
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3Cited by4 opinions
- Smith v. CommissionerUnited States Tax Court · 1985
- Estate of Ratliff v. CommissionerUnited States Tax Court · 1993
- Estate of Ratliff v. CommissionerUnited States Tax Court · 1993
- Smith v. CommissionerUnited States Tax Court · 1985