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McSORLEY'S, INC. v. UNITED STATES

No. 7289.

323 F.2d 900 (1963)

McSORLEY'S, INC., Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Tenth Circuit.

October 31, 1963.

Attorney(s) appearing for the Case

William P. Johnson, Denver, Colo. (Rothgerber, Appel & Powers, Denver, Colo., on the brief), for appellant.

Alec A. Pandaleon, Atty., Dept. of Justice (John B. Jones, Jr., Acting Asst. Atty. Gen., Meyer Rothwacks, Harry Baum and Richard J. Heiman, Attys., Dept. of Justice, and Lawrence M. Henry, U. S. Atty., of counsel, on the brief), for appellee.

Before MURRAH, Chief Judge, and PHILLIPS and BREITENSTEIN, Circuit Judges.

BREITENSTEIN, Circuit Judge.

This is a typical "thin corporation" case. The question is whether payments by a corporation to holders of its debenture notes are interest and for federal income tax purposes deductible under § 163(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 163(a). The District Director of Internal Revenue ruled that the payments were dividends rather than interest and assessed a deficiency which the corporation paid and sued to recover...

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