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TYLER v. TOMLINSON

No. 25896.

414 F.2d 844 (1969)

Jean C. TYLER and Dolly Ann Tyler, Appellants, v. Laurie W. TOMLINSON, District Director of Internal Revenue, Appellee.

United States Court of Appeals Fifth Circuit.

July 29, 1969.

Attorney(s) appearing for the Case

Samuel L. Payne, Frank C. Decker, Jacksonville, Fla., for appellants.

Johnnie M. Walters, Asst. Atty. Gen., Dept. of Justice, Washington, D. C., Richard C. Pugh, Acting Asst. Atty. Gen., Dept. of Justice, Tax Div., Washington, D. C., Lee A. Jackson, Elmer J. Kelsey, Attys., Dept. of Justice, Washington, D. C., Edward F. Boardman, U. S. Atty., Jacksonville, Fla., Mitchell Rogovin, Asst. Atty. Gen., Crombie J. D. Garrett, Marco S. Sonnenschein, Attys., Dept. of Justice, Washington, D. C., for appellee, Virginia Q. Beverly, Asst. U. S. Atty., of counsel.

Before WISDOM, THORNBERRY and GOLDBERG, Circuit Judges.

GOLDBERG, Circuit Judge:

This is another debt-equity case. We are asked once again to determine whether funds advanced to a corporation by its shareholders may be treated as Internal Revenue Code indebtedness for purposes of interest deductions, 26 U.S. C.A. § 163,1 or whether such funds are more properly considered contributions to capital and the deductions based thereon disallowed.

We begin with the year 1959 when brothers...

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