Legal Opinion
Alabama Central Credit Union v. United States
District Court, N.D. Alabama
Decided August 14, 1986No. Civ. A. 83-G-2957-SPublishedCited by 5 opinions
1Opinion of the Court
MEMORANDUM OPINION
GUIN, District Judge.
This is a civil tax suit in which the plaintiff, Alabama Central Credit Union, is seeking to recover from the defendant, United States of America, a refund in the amount of $26,492.66, for federal income taxes paid with respect to the 1977 tax year. The facts are undisputed.
Questions presented:
1. Whether securities purchased on margin or with borrowed funds constitute debt-financed property within the meaning of Section 514 of the Internal Revenue Code, so that the income derived from the debt-financed portion of the securities is taxable as unrelated…
2Cases cited5 opinions
- Alabama By-Products Corporation v. George D. Patterson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
- Louisiana Credit Union League v. The United States of AmericaCourt of Appeals for the Fifth Circuit · 1982
- Clarence Labelle Post No. 217, Veterans of Foreign Wars of the United States v. United StatesCourt of Appeals for the Eighth Circuit · 1978
- Mallette Bros. Construction Co., Inc. v. United States of America, Gautier Asphalt Company, Inc. v. United States of America, Mallette Bros. Truck Lines, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1983
- C. F. Mueller Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1973
3Cited by5 opinions
- Compania Sud-Americana De Vapores S.A. v. IBJ Schroder Bank & Trust Co.District Court, S.D. New York · 1992
- Kern County Electrical Pension Fund v. CommissionerUnited States Tax Court · 1991
- Ocean Cove Corp. Retirement Plan & Trust v. United StatesDistrict Court, S.D. Florida · 1987
- Kern County Electrical Pension Fund v. CommissionerUnited States Tax Court · 1991
- Southwest Tex. Elec. Coop. v. CommissionerUnited States Tax Court · 1994