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BRIDGES v. C.I.R.

No. 9054.

325 F.2d 180 (1963)

Joseph H. BRIDGES and Lillier J. Bridges, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided November 18, 1963.

Attorney(s) appearing for the Case

Richard E. Thigpen and Robert L. Hines, Charlotte, N. C. (Richard E. Thigpen, Jr., Charlotte, N. C., on brief), for petitioners.

Giora Ben-Horin, Atty., Dept. of Justice (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Gilbert E. Andrews, Attys., Dept. of Justice, on brief), for respondent.

Before HAYNSWORTH, BOREMAN and BRYAN, Circuit Judges.

BOREMAN, Circuit Judge.

This is an appeal from a decision of the Tax Court of the United States1 disallowing as deductions for income tax purposes payments made by the taxpayers to certain lending institutions claimed by the taxpayers to constitute payments of interest on indebtedness within the intendment of section 163(a) of the Internal Revenue Code of 1954, 26 U.S. C.A. § 163(a).2 Upon a consideration...

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