NATIONAL-STANDARD CO. v. C.I.R.

No. 83-1679.

749 F.2d 369 (1984)

NATIONAL-STANDARD COMPANY, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided December 12, 1984.


Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, Jonathan S. Cohen, Elaine F. Ferris, argued, Fred T. Goldberg, Jr., Chief Counsel, I.R.S., Washington, D.C., for respondent-appellant.

Warren C. Seieroe, McDermott, Will & Emery, James L. Malone, argued, Charles Huber, Lowell D. Yoder, Chicago, Ill., for petitioner-appellee.

Before EDWARDS and CONTIE, Circuit Judges, and WEICK, Senior Circuit Judge.


CONTIE, Circuit Judge.

The Commissioner appeals from a decision of the United States Tax Court in favor of National-Standard Company on National-Standard's petition for redetermination of a federal income tax deficiency assessed by the Commissioner. We have jurisdiction pursuant to 26 U.S.C. § 7482. We affirm.

I.

On September 17, 1970, National-Standard entered into a loan agreement pursuant to which the company borrowed 250,000,000 Luxembourg...

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