Legal Opinion
Affiliated Research, Inc. v. United States
United States Court of Claims
Decided October 15, 1965No. 315-60PublishedCited by 16 opinions
1Opinion of the Court
Collins, Judge,
delivered the.opinion of the court:
The issue in this action for the refund of corporate income taxes is whether plaintiff is entitled to a deduction for certain amounts which, according to plaintiff, constituted interest payments.1 Defendant contends that the payments in question were dividends, not interest. In order to resolve this dispute, we must determine whether the advances with respect to which the payments were made represented (1) loans to plaintiff or (2) contributions to the capital of plaintiff.
The factual background, which is set forth in detail, infra, in the…
2Cases cited11 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- United States v. DavisSupreme Court of the United States · 1962
- Dobkin v. CommissionerUnited States Tax Court · 1950
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
6 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Jack Daniel Distillery, Lem Motlow, Prop., Inc. v. The United StatesUnited States Court of Claims · 1967
- Jean C. Tyler and Dolly Ann Tyler v. Laurie W. Tomlinson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1969
- Cuyuna Realty Company v. The United StatesUnited States Court of Claims · 1967
- Ambassador Apartments, Inc. v. CommissionerUnited States Tax Court · 1968
- CMA Consol., Inc. v. Comm'rUnited States Tax Court · 2005
11 more not listed; retrieve them via the Exa API.