Legal Opinion
Fellinger v. United States
Court of Appeals for the Sixth Circuit
Decided August 5, 1966No. Nos. 16391, 16392, 16644, 16645PublishedCited by 6 opinions
1Opinion of the Court
O’SULLIVAN, Circuit Judge.
The question involved is whether $350,000 advanced by taxpayer-appellants Fellinger, Bernstein and Bamber-ger to taxpayer-appellant The Hippodrome Building Company, a corporation, in exchange for its debentures in substantially that face amount, was a bona fide loan to the company or was an investment of equity capital. The taxpayers treated the debentures as evidence of debt; the holders thereof treated the interest paid thereon as taxable income, but reported no income for payments made on the principal; the company deducted from its income the interest paid on the…
2Cases cited7 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Foresun, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965
- Gooding Amusement Company, Incorporated v. Commissioner of Internal Revenue, F. E. Gooding v. Commissioner of Internal Revenue, Anna Elizabeth Gooding v. Commissioner of Internal Revenue, F. E. Gooding and Elizabeth Gooding v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Consumers Credit Rural Electric Cooperative Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1963
- Moughon v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
2 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- J. S. Biritz Construction Co. v. Commissioner of Internal Revenue, Joseph S. Biritz and Dorothy Biritz v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1967
- Gyro Engineering Corp. v. United StatesDistrict Court, C.D. California · 1967
- Ragland Investment Co. v. CommissionerCourt of Appeals for the Sixth Circuit · 1970
- Gustin v. CommissionerUnited States Tax Court · 1968
- Herold Fellinger and Clara Fellinger v. United States of America, Maurice Bernstein and Irene Bernstein v. United States of America, the Hippodrome Building Co. v. Commissioner of Internal Revenue, Edwin I. Bamberger and Rita Bamberger v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1966
1 more not listed; retrieve them via the Exa API.