Legal Opinion

Clyde C. Pierce Corp. v. Commissioner of Internal Rev.

Court of Appeals for the Fifth Circuit

Decided June 4, 1941No. 9845PublishedCited by 21 opinions

1Opinion of the Court

HUTCHESON, Circuit Judge.

Petitioner is here leveling two complaints against the findings and order of the Board. One complaint is against the finding that monies paid it on account of interest coupons, past due when defaulted bonds of political subdivisions of the State of Florida were purchased by it, are to be treated as a return of capital, and not as a payment of interest on tax exempt securities. The other is that the taxpayer is not entitled to deduct interest paid on indebtedness incurred by it to purchase and carry the bonds in question. Petitioner, since 1932, has been a dealer in,…

Also in this document: Dissent.

2Cases cited4 opinions

  1. United States v. StewartSupreme Court of the United States · 1940
  2. Willcutts v. BunnSupreme Court of the United States · 1931
  3. Hewitt v. CommissionerUnited States Board of Tax Appeals · 1934
  4. L. A. Thompson Scenic Railway Co. v. CommissionerUnited States Board of Tax Appeals · 1928

3Cited by21 opinions

  1. Fisher v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1954
  2. Illinois Terminal Railroad Company v. The United StatesUnited States Court of Claims · 1967
  3. Shattuck v. CommissionerUnited States Tax Court · 1955
  4. National City Lines, Inc. v. United StatesCourt of Appeals for the Third Circuit · 1952
  5. Lloyd v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1946

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