MASTER LOCK CO. v. DEPARTMENT OF REVENUE

No. 335.

62 Wis.2d 716 (1974)

215 N.W.2d 529

MASTER LOCK COMPANY and another, Appellants, v. DEPARTMENT OF REVENUE, Respondent.

Supreme Court of Wisconsin.

Decided March 18, 1974.


Attorney(s) appearing for the Case

For the appellants there were briefs by Marvin E. Klitsner, John S. Skilton and Foley & Lardner, all of Milwaukee, and oral argument by Mr. Skilton.

For the respondent the cause was argued by Allan P. Hubbard, assistant attorney general, with whom on the brief was Robert W. Warren, attorney general.


HEFFERNAN, J.

This court has previously considered the deductibility of interest paid by a corporation and incurred by financing of the purchase of its own stock. The cases demonstrate that, if the purchase amounts to no more than a readjustment of internal affairs, i.e., a realignment of the interests of the individual stockholders, the interest on the debt created by the purchase is not paid in the operation of the business from which the corporate income...

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