GOLDMAN v. UNITED STATES

No. 9846.

403 F.2d 776 (1968)

Alfred D. GOLDMAN, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Tenth Circuit.

November 20, 1968.


Attorney(s) appearing for the Case

Byrne A. Bowman and Thomas F. McIntyre, Oklahoma City, Okl. (Richard F. McDivitt, Oklahoma City, Okl., with them on brief) for appellant.

Benjamin M. Parker, Dept. of Justice, Washington, D. C. (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson and Robert N. Anderson, Dept. of Justice, Washington, D. C., with him on brief) for appellee.

Before LEWIS, SETH and HICKEY, Circuit Judges.


HICKEY, Circuit Judge.

In this action the taxpayer claims a refund for deficiencies assessed and paid for taxable years 1960 and 1961. Taxpayer claimed interest deductions under 26 U.S.C. § 163(a).

In 1960 and 1961 taxpayer had insurance policies issued on the life of his brother in the amount of $100,000 and $250,000 respectively. The insurer was Western Security Life Insurance Company of Oklahoma City. Taxpayer's father was president and his brother...

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