Legal Opinion
The Kahler Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided October 5, 1973No. 72-1663PublishedCited by 32 opinions
1Opinion of the Court
ROSS, Circuit Judge.
This is an appeal from a decision of the United States Tax Court, 58 T.C. 496, favorable to the taxpayer. The Tax Court rejected the Commissioner’s allocation, under 26 U.S.C. § 482, of interest income to a parent corporation as a result of interest free loans made by the parent to its subsidiaries. We reverse with directions to enter judgment in favor of the Commissioner.
The Kahler Corporation (Kahler) has for many years owned and operated a hotel in Rochester, Minnestota. In the early 1960’s Kahler established seven wholly owned subsidiaries to operate and manage new…
2Cases cited8 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- PPG Indus., Inc. v. CommissionerUnited States Tax Court · 1970
- Huber Homes, Inc. v. CommissionerUnited States Tax Court · 1971
- Moore v. United StatesSupreme Court of the United States · 1972
3 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Pagel, Inc. v. CommissionerUnited States Tax Court · 1988
- Gehl Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- Edwards v. CommissionerUnited States Tax Court · 1976
- Fitzgerald Motor Company, Inc., and Loans, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1975
27 more not listed; retrieve them via the Exa API.