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RIALTO REALTY COMPANY, INC. v. UNITED STATES

Civ. A. No. 72-229.

366 F.Supp. 253 (1973)

RIALTO REALTY COMPANY, INC. v. UNITED STATES of America.

United States District Court, E. D. Pennsylvania.

November 2, 1973.

Attorney(s) appearing for the Case

Robert Margolis, Herbert L. Levy, Bethlehem, Pa., for plaintiff.

Donald R. Anderson, Robert J. Hipple, Dept. of Justice, Washington, D. C., for defendant.

MEMORANDUM AND ORDER

HUYETT, District Judge.

This is a federal tax refund case in which plaintiff, Rialto Realty Company, Inc., challenges defendant's disallowance of interest deductions1 taken by plaintiff for the years 1963 through 1967. The case presents the frequently litigated question whether certain corporate obligations represent debt or equity.2

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