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HARLAN v. UNITED STATES

No. 26383.

409 F.2d 904 (1969)

W. Larry HARLAN and Mary Jane Harlan, Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals Fifth Circuit.

April 4, 1969.

Attorney(s) appearing for the Case

Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Atty., Tax Div., Meyer Rothwacks, William A. Friedlander, Louis M. Kauder, Attys., Dept. of Justice, Washington, D. C., Eldon M. Mahon, U. S. Atty., Fort Worth, Tex., Martha Joe Stroud, Asst. U. S. Atty., Dallas, Tex., for defendant-appellant.

William D. Jordan, Vester T. Hughes, Jr., Larry L. Bean, Dallas, Tex. for appellees W. Larry and Mary Jane Harlan; Jackson, Walker, Winstead, Cantwell, & Miller, Dallas, Tex., of counsel.

Before AINSWORTH and SIMPSON, Circuit Judges, and MITCHELL, District Judge.

AINSWORTH, Circuit Judge:

In this taxpayer suit for refund of federal income taxes, the sole question for decision is whether certain funds advanced by shareholders to wholly owned insurance corporations at their inception, the funds being evidenced by so-called "surplus" notes, should be treated as indebtedness for tax purposes rather than contributions to capital, upon the ultimate payment of the notes. If the "surplus" notes constituted indebtedness, the payment...

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