HOOVER, INC. v. COMMISSIONER OF INTERNAL REVENUE

No. 72-1775.

474 F.2d 1050 (1973)

HOOVER, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided February 27, 1973.


Attorney(s) appearing for the Case

James Clarence Evans, Charles Carter Baker, Jr., Nashville, Tenn., for petitioner-appellant.

Scott P. Crampton, Asst. Atty. Gen., Tax Div., Lee H. Henkel, Jr., I.R.S., Richard Farber, Washington, D.C., for respondent-appellee.

Before PECK and KENT, Circuit Judges, and YOUNG, District Judge.


ORDER

This is an appeal from the Tax Court's holding that the appellant in substance acted merely as a conduit by which its controlling shareholder, as guarantor of a loan, paid the debt owed by John L. Burns, Inc. to a bank, and, therefore, the appellant taxpayer was not entitled to any deduction arising out of the transaction. Clearly, our review of tax court decisions is the same as the standard applied in the review of District Court decisions. Kunz v. C.I.R...

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