Legal Opinion
Staked Plains Trust, Ltd. v. Commissioner
Court of Appeals for the Fifth Circuit
Decided June 28, 1944No. 10980PublishedCited by 5 opinions
1Opinion of the Court
LEE, Circuit Judge.
In its income tax return for 1937 petitioner deducted the sum of $29,750 as interest accrued on indebtedness under Section 23(b) of the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Code, § 23(b). The .Commissioner disallowed the deduction on the ground that the sum did not represent interest due on an indebtedness. The Tax Court sustained the Commissioner and the taxpayer brought the case here for review.
The taxpayer, a trust taxable as a corporation, was formed in 1914 to take over and develop or sell in subdivisions a tract of 60,000 acres of land in Texas acquired in 1912 by…
2Cases cited15 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- South Chicago Coal & Dock Co. v. BassettSupreme Court of the United States · 1940
- United States v. South Georgia Ry. Co.Court of Appeals for the Fifth Circuit · 1939
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3Cited by5 opinions
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956
- Farley Realty Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1960
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- Unitex Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Kraft Foods Company v. Commissioner of Internal Revenue, (Two Cases)Court of Appeals for the Second Circuit · 1956