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KARNS PRIME & FANCY FOOD, LTD. v. C.I.R.

No. 06-1031.

494 F.3d 404 (2007)

KARNS PRIME & FANCY FOOD, LTD., Appellant v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Filed: July 20, 2007.

Attorney(s) appearing for the Case

Steven J. Schiffman, John D. Sheridan (Argued), Serratelli, Schiffman, Brown & Calhoun, Harrisburg, PA, for Appellant.

Richard Farber, Bethany B. Hauser (Argued), United States Department of Justice, Washington, DC, for Appellee.

Before: SLOVITER, AMBRO, Circuit Judges, and BRODY, District Judge.

OPINION OF THE COURT

SLOVITER, Circuit Judge.

The distinction between a loan and an advance payment for the purpose of whether the funds received are to be treated as "income" subject to federal income tax is not always apparent on the face of the documents. Instead, the issue is to be determined after an examination of "all the facts and circumstances." Comm'r v. Indianapolis Power & Light Co., 493 U.S. 203, 207...

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