Legal Opinion
P. M. Finance Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided May 10, 1962No. 13713, 13714PublishedCited by 50 opinions
1Opinion of the Court
BIGGS, Chief Judge.
The petitions for review raise the question of deductibility, pursuant to Section 163(a) of the Internal Revenue Code of 1954, 1 of “interest on indebtedness” paid by P. M. Finance Corporation to two debenture holders, one of whom, Philip Frank, owns the outstanding capital stock of the corporation. The other debenture holder is Philip’s wife, Hilda. The Tax Court decided that the payments made by P. M. were not deductible as interest on indebtedness. It sustained the Commissioner’s determination of income tax deficiencies against P. M. for the taxable years ending May 31,…
2Cases cited24 opinions
- White v. United StatesSupreme Court of the United States · 1938
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- Benjamin D. And Madeline Prentice Gilbert, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1959
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
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3Cited by50 opinions
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
- Alterman Foods, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Charter Wire, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1962
- O'HAZZA v. Executive Credit Corp.Supreme Court of Virginia · 1993
- Diamond Bros. Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1963
45 more not listed; retrieve them via the Exa API.