242 F2d 759 Corporation v. Commissioner of Internal Revenue

242 F.2d 759

241 CORPORATION, Petitioner,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.

No. 186.

Docket 24359.

United States Court of Appeals Second Circuit.

Argued March 5, 6, 1957.

Decided March 28, 1957.

Petition to review a decision of the Tax Court; Stephen E. Rice, Judge.

The Tax Court disallowed deductions claimed as interest paid on indebtedness under Internal Revenue Code of 1939, Section 23(b), 26 U.S.C.A. § 23(b), holding that advances made by stockholders to the taxpayer corporation were capital contributions rather than loans. T.C. Memo. 1956-174.

Bernard Weiss, New York City, for petitioner.

Charles K. Rice, Asst. Atty. Gen. (Lee A. Jackson and Morton K. Rothschild, Attorneys, Department of Justice, Washington, D. C.,), for respondent.

Before MEDINA and WATERMAN, Circuit Judges, and GALSTON, District Judge.

PER CURIAM.

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Affirmed on the findings of fact and opinion of Judge Rice, T.C.Memo. 1956-174.