Legal Opinion
Community Loan & Investment Corp. v. United States
District Court, N.D. Georgia
Decided March 23, 1965No. Civ. A. No. 8800Published
1Opinion of the Court
HOOPER, Chief Judge.
The plaintiff, doing business in Georgia as a small loan company, brought this action seeking to recover an alleged overpayment of income taxes. All of the material facts in the case are stipulated by the parties. The sole question is whether or not under the facts in the record certain certificates issued by the plaintiff to parties borrowing money from the plaintiff shall be considered as bor« *435rowed capital pursuant to Internal Revenue Code of 1939, § 439.
The taxpayer conducted its business during the applicable period of time as follows: The prospective borrower filled…
2Cases cited2 opinions
- Commissioner of Internal Revenue v. Valley Morris Plan, Formerly the Stockton Morris Plan Company, Commissioner of Internal Revenue v. The Morris Plan Company of CaliforniaCourt of Appeals for the Ninth Circuit · 1962
- North American Finance Corporation of Savannah v. The United StatesUnited States Court of Claims · 1963