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CUYUNA REALTY COMPANY v. UNITED STATES

No. 326-63.

382 F.2d 298 (1967)

CUYUNA REALTY COMPANY v. The UNITED STATES.

United States Court of Claims.

July 20, 1967.

Attorney(s) appearing for the Case

Quinn O'Connell, Washington, D. C., for plaintiff; Robert T. Molloy, Washington, D. C., attorney of record; Gerald J. O'Rourke, Jr., and Weaver, Glassie & Molloy, Washington, D. C., of counsel.

Joseph Kovner, Washington, D. C., with whom was Asst. Atty. Gen., Mitchell Rogovin, for defendant; Philip R. Miller and Richard J. Boyle, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS, COLLINS, SKELTON and NICHOLS, Judges.

OPINION

LARAMORE, Judge.*

This is but another version of the debt-versus-equity controversy arising so frequently in the tax field. The facts are simple; they involve the deductibility of accrued and unpaid interest on demand notes given to a parent corporation by its wholly-owned and always-insolvent subsidiary.

In 1912 Cuyuna was organized under Minnesota laws as a subsidiary of Northwestern Improvement Company (NWI...

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