(Download) "Trans-Atlantic Co. v. Commissioner of Internal Revenue" by United States Court of Appeals for the Third Circuit * Book PDF Kindle ePub Free

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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. Â§ 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