SALLEY v. C. I. R.

No. 71-3122 Summary Calendar.

464 F.2d 479 (1972)

Rufus C. SALLEY and Beulah S. Salley, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

July 24, 1972.


Attorney(s) appearing for the Case

J. L. Rothchild, Houston, Tex., for petitioners-appellants.

Scott P. Crampton, Asst. Atty. Gen., Tax Div., Dept. of Justice, K. Martin Worthy, Chief Counsel, Eugene F. Colella, I.R.S., Washington, D. C., for respondent-appellee.

Before JOHN R. BROWN, Chief Judge, and GOLDBERG and MORGAN, Circuit Judges.


GOLDBERG, Circuit Judge:

Taxpayers, Rufus C. Salley and Beulah S. Salley, in search of the ever-elusive grail of the "tax loophole," appeal from a determination by the Tax Court that so-called interest payments on loans from their controlled insurance company are not deductible under 26 U.S.C.A. §§ 163(a), 162(a), or 212(1).1 55 T.C. 896 (1971). We agree with the Tax Court that the alleged loans...

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