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GOLDER v. C. I. R.

No. 77-1542.

604 F.2d 34 (1979)

Lloyd W. GOLDER, Jr. and Esther Golder, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Ninth Circuit.

Rehearing Denied September 20, 1979.

Attorney(s) appearing for the Case

G. Eugene Isaak (argued), of Miller, Pitt & Feldman, P. C., Tucson, Ariz., on brief, for appellants.

Myron C. Baum, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D. C., on brief; Jonathan S. Cohen, Tax Div., Dept. of Justice, Washington, D. C., for appellee.

Before DUNIWAY and WALLACE, Circuit Judges, and BLUMENFELD, District Judge.

BLUMENFELD, District Judge:

Taxpayers, Lloyd and Esther Golder, appeal the decision of the United States Tax Court which held that they could not deduct as interest under section 163(a) of the Internal Revenue Code of 1954 (I.R.C.) payments they made as guarantors of corporate obligations of their closely-held corporation. We affirm.

Facts

The Golders (hereinafter taxpayers) were majority shareholders...

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