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TOMLINSON v. 1661 CORPORATION

No. 23246.

377 F.2d 291 (1967)

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

United States Court of Appeals Fifth Circuit.

May 9, 1967.

Attorney(s) appearing for the Case

Mitchell Rogovin, Asst. Atty. Gen., Richard M. Roberts, C. Moxley Featherston, Acting Asst. Attys. Gen., Lee A. Jackson, Harry Marselli, Meyer Rothwacks, Gilbert E. Andrews, Solomon L. Warhaftig, Attys., Dept. of Justice, Washington, D. C., Edward F. Boardman, U. S. Atty., Tampa, Fla., Virginia Q. Beverly, Asst. U. S. Atty., Jacksonville, Fla., for appellant.

William T. Rogers, Judson Freeman, Jacksonville, Fla., for appellee.

Before MARIS, BROWN and THORNBERRY, Circuit Judges.

JOHN R. BROWN, Circuit Judge:

The only question presented on this appeal is whether certain advances of funds to the Taxpayer Corporation1 by its sole shareholders constitutes indebtedness within the meaning of § 163 of the Internal Revenue Code of 1954, 26 U.S.C.A. § 163,2 or contributions to capital. The Commissioner determined that the advances fell into the capital category and disallowed the...

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