GHEEN v. C.I.R.

No. 15541.

331 F.2d 470 (1964)

Bruce I. GHEEN and Jean Gheen, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Sixth Circuit.

May 8, 1964.


Attorney(s) appearing for the Case

W. Dean Hopkins, Cleveland, Ohio (W. Dean Hopkins, H. Guy Hardy, McDonald, Hopkins & Hardy, Cleveland, Ohio, on the brief), for petitioners.

George F. Lynch, Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Gilbert A. Andrews, Jonathan S. Cohen, Attys., Department of Justice, Washington, D. C., on the brief), for respondent.

Before WEICK, Chief Judge, and O'SULLIVAN and PHILLIPS, Circuit Judges.


PHILLIPS, Circuit Judge.

Petitioners seek a review of the decision of the Tax Court of the United States holding that claimed interest payments deducted by petitioners on their federal income tax returns for 1957 and 1958 did not qualify as "interest * * * on indebtedness" within the meaning of Section 163(a) of the Internal Revenue Code of 1954, 26 U.S.C.A. § 163(a).

Petitioners filed joint income tax returns as husband and wife for 1957 and 1958 with...

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