NATIONAL FARMERS UNION SERVICE CORP. v. UNITED STATES

No. 9651.

400 F.2d 483 (1968)

NATIONAL FARMERS UNION SERVICE CORPORATION, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Tenth Circuit.

September 23, 1968.


Attorney(s) appearing for the Case

Stanley L. Drexler, Denver, Colo. (Drexler & Wald Professional Co., and Charles F. Brannan, Denver, Colo., with him on the brief), for appellant.

Gilbert E. Andrews, Jr., Washington, D. C. (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, and Willy Nordwind, Jr., Attys., Dept. of Justice, Washington, D. C., Lawrence M. Henry, U. S. Atty., and David I. Shedroff, Asst. U. S. Atty., Denver, Colo., of counsel, with him on the brief), for appellee.

Before MURRAH, Chief Judge, and PICKETT and SETH, Circuit Judges.


SETH, Circuit Judge.

This appeal has been taken from a judgment by the trial court which dismissed part of appellant taxpayer's claim for refund of federal corporate income taxes. The taxpayer claimed a refund for the years 1955 and 1957 based upon loss carry-backs. In computing the losses taxpayer deducted certain payments it had made as interest on promissory notes given to its parent corporation, National Farmers Union. The Commissioner disallowed these deductions...

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