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HALLE v. C.I.R.

No. 95-1740.

83 F.3d 649 (1996)

Warren E. HALLE; Martha D. Halle, Partners Other Than the Tax Matters Partner, Petitioners-Appellants, and Kingstowne L. P., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided May 6, 1996.

Attorney(s) appearing for the Case

ARGUED: Patrick G. Dooher, Silverstein & Mullens, Washington, D.C., for Appellants. Jonathan Samuel Cohen, Tax Division, United States Department of Justice, Washington, D.C., for Appellee. ON BRIEF: Loretta C. Argrett, Assistant Attorney General, Gary R. Allen, Kevin M. Brown, Tax Division, United States Department of Justice, Washington, D.C., for Appellee.

Before NIEMEYER and MICHAEL, Circuit Judges, and PHILLIPS, Senior Circuit Judge.

OPINION

NIEMEYER, Circuit Judge:

We are presented with the question of whether the taxpayer may deduct as interest under I.R.C. § 163(a) $900,000 in payments it made to defer the closing date of a stock purchase agreement that obligated it to buy all of a corporation's capital stock. Because the stock purchase agreement contained a liquidated damages clause limiting the taxpayer's liability on default, the Commissioner of Internal Revenue concluded...

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