1. Home
  2. Browse Decisions
  3. F.2d
  4. 500 F.2d
  5. 500 F.2d 108 (1974)
 

KERRY INVESTMENT COMPANY v. C. I. R.

Nos. 73-1084, 73-1137.

500 F.2d 108 (1974)

KERRY INVESTMENT COMPANY, a Washington corporation, Petitioner-Appellant-Cross-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee-Cross-Appellant.

United States Court of Appeals, Ninth Circuit.

June 6, 1974.

Attorney(s) appearing for the Case

Meyer Rothwacks, Richard W. Perkins, Stephen Schwarz, Scott P. Crampton, Asst. Atty. Gen., Tax Div., U. S. Dept. of Justice, Washington, D. C., for petitioner-appellant-cross-appellee.

James W. Johnston of Graham, McCord, Dunn, Moen, Johnston & Rosenquist, Seattle, Wash., for respondent-appellee-cross-appellant.

Before ELY and GOODWIN, Circuit Judges, and WILLIAMS, District Judge.

OPINION

ELY, Circuit Judge:

The taxpayer made interest-free loans totaling over $500,000 to a subsidiary corporation wholly owned by the taxpayer. The Commissioner, acting pursuant to section 482 of the Internal Revenue Code of 1954 (26 U.S.C. § 482) and certain Treasury Regulations adopted thereunder (26 C.F.R. §§ 1.482-1 and 1.482-2), allocated interest income to the taxpayer for the years in question, 1966 and 1967. Except as to one loan...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases