Legal Opinion
Perry Nichols and Inez Nichols v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided March 6, 1963No. 19706PublishedCited by 41 opinions
1Per curiam
These are consolidated appeals from the Tax Court involving deficiencies in* income taxes. 37 T.C. 772. The claimed interest deductions under § 163(a) of the* Internal Revenue Code of 1954, Title 26* U.S.C.A. § 163(a), were properly disallowed. There was no bona fide indebtedness at any time as required by the statute, and thus no “compensation for the use or forbearance of money.” Deputy v. DuPont, 1940, 308 U.S. 488, 60 S.Ct. 363, 84 L.Ed. 416.
In sum, taxpayers were led into the hands of M. Eli Livingstone who offered an enticing plan to save income taxes through deductions for the payment…
2Cases cited7 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
- United States v. General Geophysical CompanyCourt of Appeals for the Fifth Circuit · 1961
- Lynch v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Broome v. United StatesUnited States Court of Claims · 1959
2 more not listed; retrieve them via the Exa API.
3Cited by41 opinions
- Bridges v. CommissionerUnited States Tax Court · 1963
- Nichols v. CommissionerUnited States Tax Court · 1965
- Leslie H. Jockmus and Esther N. Jockmus v. United StatesCourt of Appeals for the Second Circuit · 1964
- Charles B. Benenson and Dorothy Cullman v. United StatesCourt of Appeals for the Second Circuit · 1967
- James A. Dooley and Virginia P. Dooley v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
36 more not listed; retrieve them via the Exa API.