GIBLIN v. COMMISSIONER OF INTERNAL REVENUE

No. 15587.

227 F.2d 692 (1955)

Vincent C. GIBLIN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fifth Circuit.

November 23, 1955.


Attorney(s) appearing for the Case

Hilton R Carr, Jr., Herbert A. Warren, Jr., Vincent C. Giblin, Miami, Fla., for petitioner.

John Potts Barnes, Chief Counsel, Internal Revenue Service, Chicago, Ill., Rollin H. Transue, Sp. Atty., Internal Revenue Service, Washington, D. C., H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack, Karl Schmeidler, Attys., Department of Justice, Washington, D. C., for respondent.

Before RIVES, TUTTLE and JONES, Circuit Judges.


TUTTLE, Circuit Judge.

This is a petition for review of a decision of the Tax Court involving income taxes for 1945. The questions presented for our consideration are two. First, whether loans made by taxpayer to a corporation, of which he was an officer, director, large stockholder and principal actor, are deductible in full as a business bad debt under Section 23(k) (1) of the Internal Revenue Code of 1939, 26 U.S. C.A., or whether these loans are deductible only...

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