PARISIAN, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 10361.

131 F.2d 394 (1942)

PARISIAN, Inc., v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fifth Circuit.

November 10, 1942.


Attorney(s) appearing for the Case

Benj. Leader, John D. Hill, and Samuel Tenenbaum, all of Birmingham, Ala., for petitioner.

J. P. Wenchel, Chief Counsel, and Claude R. Marshall, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, Helen R. Carloss, and Willard H. Pedrick, Sp. Assts. to Atty. Gen., for respondent.

Before HUTCHESON, HOLMES, and McCORD, Circuit Judges.


HUTCHESON, Circuit Judge.

What is in question here is whether payments made as dividends on preferred stock were in fact dividends or were interest paid on indebtedness within and therefore deductible under Section 23 (b), Revenue Act of 1938, 26 U.S.C.A. Int. Rev.Code, § 23(b). The Board thought the obligations were, as they purported to be, certificates of stock, and the payments were, as they purported to be, and were treated as, dividends on stock. It sustained...

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