Legal Opinion
Claussen's, Inc. v. United States
Court of Appeals for the Fifth Circuit
Decided November 16, 1972No. 72-1050PublishedCited by 4 opinions
1Opinion of the Court
TUTTLE, Circuit Judge:
This is a tax ease involving the question whether amortizable bond discount was incurred by taxpayer’s predecessor when it issued debentures to its stockholders in connection with a recapitalization of its common stock. The district court held that bond discount did arise as a result of the transaction and, accordingly, that the predecessor to the taxpayer was entitled to a discount deduction, in the amount of $295,282.50, on its final federal income tax return. We reverse.
The facts are not disputed. Claus-sen’s Bakeries, Inc. (hereafter Bakeries) was organized in 1954…
2Cases cited16 opinions
- Bazley v. CommissionerSupreme Court of the United States · 1947
- United States v. DavisSupreme Court of the United States · 1970
- Helvering v. Union Pacific RailroadSupreme Court of the United States · 1934
- Nassau Lens Co., Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Harry Pildes and Sarah PildesCourt of Appeals for the Second Circuit · 1962
- United States v. Midland-Ross Corp.Supreme Court of the United States · 1965
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3Cited by4 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Gulf, Mobile and Ohio Railroad Company, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Fifth Circuit · 1978
- National Alfalfa Dehydrating and Milling Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
- National Alfalfa Dehydrating and Milling Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973