Legal Opinion
Austin Village, Inc. v. United States
District Court, N.D. Ohio
Decided December 10, 1968No. Civ. A. No. C 65-89PublishedCited by 7 opinions
1Opinion of the Court
MEMORANDUM
BEN C. GREEN, District Judge.
This is a suit for refund of income taxes in the amount of $622.95 plus statutory interest for the year 1958. Deficiencies for other years are being held in abeyance at the administrative level pending the decision herein.
The issue in this action is whether certain advances made by stockholders to the plaintiff corporation were loans, so as to entitle the plaintiff to deduct accrued interest thereon for income tax purposes, 26 U.S.C. § 163.
The plaintiff corporation came into existence in 1953 as the outgrowth of a land transaction entered into by certain…
2Cases cited8 opinions
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- Byerlite Corporation v. Parker C. Williams, District Director of Internal Revenue, Eighteenth District of OhioCourt of Appeals for the Sixth Circuit · 1960
- George T. Smith and Clela v. Smith v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1966
- 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
- Arlington Park Jockey Club, Inc. v. SauberCourt of Appeals for the Seventh Circuit · 1959
3 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Indmar Products Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- Austin Village, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 1970
- Theodore B. Livernois Trust of May 2, 1958, Theodore B. Livernois, Jr., and Albert L. Grigsby, Jr., Trustees v. Commissioner of Internal Revenue, Alma G. Livernois v. Commissioner of Internal Revenue, Alma G. Livernois, Petitioner-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Cross-AppellantCourt of Appeals for the Sixth Circuit · 1970
- Austin Village, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 1970
- Indmar Products Co v. CIRCourt of Appeals for the Sixth Circuit · 2006
2 more not listed; retrieve them via the Exa API.