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PIASA FIRST FEDERAL SAVINGS & LOAN ASS'N v. UNITED STATES

No. 18355.

441 F.2d 399 (1971)

PIASA FIRST FEDERAL SAVINGS AND LOAN ASSOCIATION, a United States Corporation, Plaintiff-Appellant, v. The UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Rehearing Denied May 5, 1971.

Attorney(s) appearing for the Case

Robert E. Ryan, Ryan & Mondhink, Alton, Ill., for plaintiff-appellant.

Frank J. Violanti, U. S. Atty., Springfield, Ill., Johnnie M. Walters, Asst. Atty. Gen., Lee A. Jackson, William Massar, Issie L. Jenkins, Attys., Dept. of Justice, Washington, D. C., for defendant-appellee.

Before DUFFY, Senior Circuit Judge, FAIRCHILD, Circuit Judge, and CAMPBELL, Senior District Judge.

DUFFY, Senior Circuit Judge.

This suit was brought by the Piasa First Federal Savings and Loan Association (Piasa) for the recovery of $6,256.82 plus interest, for the calendar year 1963. The case was submitted to the District Court on a stipulation of facts and briefs.

The issue before us is whether the corporate tax payer (Piasa) is entitled to deduct interest income received in 1963 on debentures of the Federal Housing Administration, which were not issued...

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