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H ENTERPRISES INTERN., INC. v. C.I.R.

No. 98-3259.

183 F.3d 907 (1999)

H ENTERPRISES INTERNATIONAL, INC., and Subsidiaries, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided July 27, 1999.

Rehearing Denied October 8, 1999.

Attorney(s) appearing for the Case

William H. Hippee, Jr., Minneapolis, MN, argued (Edward J. Pluimer and Mary J. Streitz, Minneapolis, MN, on the brief), for appellant.

Steven W. Parks, Dept. of Justice, Washington, D.C., argued (Richard Farber, Dept. of Justice, on the brief), for appellee.

Before RICHARD S. ARNOLD, FAGG, and BOWMAN, Circuit Judges.

PER CURIAM.

This is an income-tax case. Two issues are presented: whether H Enterprises International, Inc., is entitled to a dividends-received deduction with respect to certain distributions made to it by a subsidiary, Waldorf Corporation; and whether Waldorf is entitled to an interest deduction for certain indebtedness incurred by it.

The Commissioner asserts, and the Tax Court held, that H Enterprises was not entitled to the dividends-received deduction...

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