HORNE v. C.I.R.

No. 73-2349.

523 F.2d 1363 (1975)

M. Seth HORNE and Maurine D. Horne, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

September 30, 1975.


Attorney(s) appearing for the Case

Hubert E. Kelly (argued), Kelly & Corbin, Phoenix, Ariz., for petitioners.

Elmer J. Kelsey, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent.

Before CHAMBERS, Circuit Judge, BALDWIN, Judge of the Court of Customs and Patent Appeals, and WALLACE, Circuit Judge.


OPINION

CHAMBERS, Circuit Judge:

The issue in this case is whether payments of approximately $300,000 made by taxpayer M. Seth Horne as indemnitor in connection with obligations of corporations in which he owned a substantial interest are deductible as ordinary losses. Horne was the principal partner in a real estate development firm which owned all the outstanding shares of James Stewart and Co., Inc. (COINC). COINC had two wholly-owned subsidiaries, James...

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