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AMERICAN BODY AND EQUIPMENT CO. v. UNITED STATES

No. 74-2756.

511 F.2d 647 (1975)

AMERICAN BODY AND EQUIPMENT COMPANY, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Fifth Circuit.

April 16, 1975.

Attorney(s) appearing for the Case

Charles G. Barnett, James A. Knox, Dallas, Tex., for plaintiff-appellant.

Frank D. McCown, U. S. Atty., Ft. Worth, Tex., Martha Joe Stroud, Asst. U. S. Atty., Dallas, Tex., Scott P. Crampton, Asst. Atty. Gen., John E. Lutz, Ernest J. Brown, Myron C. Baum, Attys., Dept. of Justice, Tax Div., Washington, D. C., Howard A. Weinberger, Tax Div., Dept. of Justice, Dallas, Tex., for defendant-appellee.

Before BELL, THORNBERRY and GEE, Circuit Judges.

BELL, Circuit Judge:

This appeal is brought from a judgment by the district court denying appellant taxpayer's claim for a $3,302.84 refund on federal income taxes assessed and collected for fiscal year ending August 31, 1968. The court rejected appellant's contention that it should have been allowed to deduct interest paid on insurance policy loans under Section 264(c)(4) of the Internal Revenue Code of 1954.1 We affirm.

In 1963...

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