1661 CORPORATION v. TOMLINSON

No. 64-171-Civ-J.

247 F.Supp. 936 (1965)

The 1661 CORPORATION, Plaintiff, v. Laurie W. TOMLINSON, District Director of Internal Revenue for the District of Florida, Defendant.

United States District Court M. D. Florida, Jacksonville Division.

September 16, 1965.


Attorney(s) appearing for the Case

William T. Rogers, Donahoo & Rogers, Judson Freeman, Bryant, Freeman, Richardson & Watson, Jacksonville, Fla., for plaintiff.

Edward F. Boardman, U. S. Atty., Jacksonville, Fla., J. Patrick Whaley, Atty., Tax Division, Dept. of Justice, Washington, D. C., for defendant.


McRAE, District Judge.

This is a suit for refund of income taxes and interest claimed by plaintiff to have been illegally and erroneously assessed against and collected from plaintiff by defendant for the years 1960, 1961 and 1962.

Upon audit by defendant of plaintiff's income tax return for each of these years, a claimed deduction for interest paid or accrued on debentures issued by plaintiff to its stockholders was disallowed on the grounds that the debentures...

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