Legal Opinion
Heart of Atlanta Motel, Inc. v. United States
District Court, N.D. Georgia
Decided November 19, 1962No. Civ. A. No. 7628Published
1Opinion of the Court
MORGAN, District Judge.
On August 20,1962, the plaintiff Heart of Atlanta Motel, Inc., proceeding under the provisions of Rule 56 of the Federal Rules of Civil Procedure, filed a motion for a partial summary judgment in plaintiff’s favor on the issue of the deductibility by plaintiff for federal income tax purposes of interest accrued on loans from its stockholders, on the ground that there is no genuine issue as to any material fact, and that the plaintiff is entitled to a judgment in its favor on this issue as a matter of law. There is another issue in the case involving the proper rate of…
2Cases cited5 opinions
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- John v. Rowan v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- Universal Castings Corporation, an Illinois Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1962
- Bijou-Pensacola Corporation v. United StatesDistrict Court, N.D. Florida · 1959
- Southern Rail & Equipment Co. v. Midwest Mfg. & Plating Co.Court of Appeals for the Seventh Circuit · 1949