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ALLEN H. DAHME ASSOCIATES, INC. v. UNITED STATES

No. 306-65.

436 F.2d 486 (1971)

ALLEN H. DAHME ASSOCIATES, INC. v. The UNITED STATES.

United States Court of Claims.

January 22, 1971.

Attorney(s) appearing for the Case

Platt W. Dockery, Grand Rapids, Mich., attorney of record, for plaintiff. Warner, Norcross & Judd, Grand Rapids, Mich., of counsel.

Kenneth R. Boiarsky, Washington, D. C., with whom was Asst. Atty. Gen. Johnnie M. Walters, for defendant. Philip R. Miller and Joseph Kovner, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS, COLLINS, SKELTON, and NICHOLS, Judges.

OPINION

COLLINS, Judge.*

In this income tax refund case we are forced to deal with the concept of goodwill — one of the most troublesome in the law of taxation. The plaintiff taxpayer is suing to recover income tax paid (plus interest) by virtue of the disallowance by the Commissioner of Internal Revenue of amounts sought to be deducted under section 163 of the code1 as interest paid or accrued...

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