Legal Opinion

Thomas M. Ferrill, Jr. And Louise B. Ferrill v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided August 6, 1982No. 81-2242PublishedCited by 28 opinions

1Opinion of the Court

OPINION OF THE COURT

2Per curiam

In this appeal from a decision by the Tax Court in favor of the Commissioner of Internal Revenue, the appellants, Thomas and Louise Ferrill, claim that the Tax Court erred in disallowing a deduction of prepaid interest and in permitting an amended answer by the Commissioner. Because we conclude that the Tax Court neither committed an error of law nor abused its discretion, we affirm.

I

The Ferrills were cash basis taxpayers who filed a joint return for the calendar year 1972. Earlier in that year, they investigated the possibility of establishing a restaurant franchise, in…

3Cases cited11 opinions

  1. Commissioner v. HansenSupreme Court of the United States · 1959
  2. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961
  3. Sandor v. CommissionerUnited States Tax Court · 1974
  4. Ft. Howard Paper Co. v. CommissionerUnited States Tax Court · 1967
  5. Andrew A. Sandor and Jeanne Sandor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976

6 more not listed; retrieve them via the Exa API.

4Cited by28 opinions

  1. Prabel v. CommissionerUnited States Tax Court · 1988
  2. Bruce A. And Marianne S. Prabel v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1989
  3. Law v. CommissionerUnited States Tax Court · 1985
  4. Estate of Quick v. CommissionerUnited States Tax Court · 1998
  5. Evans Publ'g, Inc. v. Comm'rUnited States Tax Court · 2002

23 more not listed; retrieve them via the Exa API.

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