Legal Opinion
Wilkerson v. Commissioner
Court of Appeals for the Ninth Circuit
Decided September 8, 1981No. 79-7519PublishedCited by 16 opinions
1Opinion of the Court
SCHROEDER, Circuit Judge:
The Commissioner of Internal Revenue appeals from a decision of the Tax Court finding that interest remitted by the taxpayers out of an advance on loan proceeds was “paid” within the meaning of Internal Revenue Code § 163(a), 26 U.S.C. § 163(a)1 in the year for which the interest deduction was claimed.
Appellees are members of two limited partnerships, Willowbrook Apartments (Willowbrook) and Meadows East which were formed for the purpose of developing and constructing apartment complexes. Each partnership obtained a loan in excess of $3,000,000 from Mason-McDuffie…
2Cases cited18 opinions
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
- Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. GoodsteinCourt of Appeals for the First Circuit · 1959
- Helvering v. PriceSupreme Court of the United States · 1940
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- G. Douglas Burck and Marjorie W. Burck v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
13 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Blitzer v. United StatesUnited States Court of Claims · 1982
- H. C. Franklin and Marjorie Franklin v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1982
- Menz v. CommissionerUnited States Tax Court · 1983
- Noble v. CommissionerUnited States Tax Court · 1982
- Davison v. CommissionerUnited States Tax Court · 1996
11 more not listed; retrieve them via the Exa API.