[Download] "Trans-Atlantic Co. v. Commissioner of Internal Revenue" by United States Court of Appeals for the Third Circuit # Book PDF Kindle ePub Free
eBook details
- Title: Trans-Atlantic Co. v. Commissioner of Internal Revenue
- Author : United States Court of Appeals for the Third Circuit
- Release Date : January 21, 1972
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 71 KB
Description
Opinion OF THE COURT VAN DUSEN, Circuit Judge. The question in this case is whether payments made on various obligations of Trans-Atlantic were deductible as interest under 26 U.S.C. § 163(a) (1970) or were in reality disguised dividends.1 The Commissioner determined that they were dividends, and, therefore, assessed deficiencies of $7,849.50, $7,336.73, and $6,662.61 for the taxable years ending January 31, 1964, 1965, and 1966. The Tax Court affirmed, T.C. Memo 1970-307, 29 CCH Tax Ct.Mem. 1414 (1970), and Trans-Atlantic appeals that decision.2
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