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KNETSCH v. UNITED STATES

No. 23.

364 U.S. 361 (1960)

KNETSCH ET UX. v. UNITED STATES.

Supreme Court of United States.

Decided November 14, 1960.

Attorney(s) appearing for the Case

W. Lee McLane, Jr. argued the cause for petitioners. With him on the brief was Nola M. McLane.

Grant W. Wiprud argued the cause for the United States. With him on the brief were Solicitor General Rankin, Assistant Attorney General Rice and Harry Baum.

Richard H. Appert, Converse Murdoch and Douglas W. McGregor filed briefs, as amici curiae, urging reversal.

MR. JUSTICE BRENNAN delivered the opinion of the Court.

This case presents the question of whether deductions from gross income claimed on petitioners' 1953 and 1954 joint federal income tax returns, of $143,465 in 1953 and of $147,105 in 1954, for payments made by petitioner, Karl F. Knetsch, to Sam Houston Life Insurance Company, constituted "interest paid . . . on indebtedness" within the meaning of § 23 (b) of the Internal Revenue Code of 1939 and §...

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