Carl E. WELLER and Emily I. Weller, Petitioners,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
W. Stuart EMMONS, Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
United States Court of Appeals Third Circuit.https://leagle.com/images/logo.png
Argued June 9, 1959.
Decided September 9, 1959.
Attorney(s) appearing for the Case
Richard H. Appert, New York City (John A. Garvey, Jr., New York City, Harry A. Dower, Allentown, Pa., White & Case, New York City, Perkin, Twining & Dower, Allentown, Pa., on the brief), for petitioners Weller.
Kenneth W. Gemmill, Philadelphia, Pa. (Converse Murdoch, P. J. DiQuinzio, Bruce S. Cronlund, Philadelphia, Pa., on the brief), for petitioner Emmons.
Grant W. Wiprud, Washington, D. C. (Howard A. Heffron, Acting Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Attys. Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., on the brief), for respondent.
Before BIGGS, Chief Judge, and McLAUGHLIN and STALEY, Circuit Judges.
United States Court of Appeals Third Circuit.
STALEY, Circuit Judge.
These cases present identical questions of law,1 namely, whether the Tax Court erred in holding that certain transactions involving prepayment of interest on annuity contract loans lacked substance so as not to be deductible as interest payments under Section 23(b) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 23(b).
The essential facts in the Emmons case, as found by the Tax Court, may be summarized...
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