GINSBURG, Circuit Judge:
Cerand & Co., Inc. (Cerand) appeals from a judgment of the tax court predicated upon that court's conclusion that payments Cerand made to three of its sister corporations were intended to be capital contributions rather than loans. We hold that the tax court erred in failing to consider the fact seemingly most probative of the proper classification of the payments — that the taxpayer over several years treated as taxable interest...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.
