Karns Prime & Fancy Food, Ltd. v. Comm'r of Internal Revenue, 06-1031
In case where appellant grocery store chain borrowed $1.5 million from its principal supplier to make capital improvements with agreements to repay and have the suppler be the principal wholesaler, Tax Court correctly decided that $1.5 million from appellant's supplier was not a loan and thus was includable in gross income.
- Argued 03/05/2007
- Decided 07/20/2007
- Published 07/20/2007
- Before: SLOVITER, AMBRO, Circuit Judges, and BRODY, District Judge.
- United States Third Circuit
- For Appellant:
- Steven J. Schiffman, John D. Sheridan (Argued), Serratelli, Schiffman, Brown & Calhoun, Harrisburg, PA, for Appellant.
- For Appellees:
- Richard Farber, Bethany B. Hauser (Argued), United States Department of Justice, Washington, DC, for Appellee.