United States Sixth Circuit

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AM. ELEC. POWER CO. v. US, 01-3495

A corporate-owned life insurance plan was an economic sham, thus deductions of interest due on loans made against the policies from federal income tax were properly disallowed, and additional assessment of taxes for the year in question is affirmed.

Appellate Information

  • Decided 04/28/2003
  • Published 04/28/2003

Judges

  • Before NELSON, COLE, and GILMAN, Circuit Judges.

Court

  • United States Sixth Circuit

Counsel

  • For Appellant:
  • Randolph Carson Wiseman (briefed), Bricker & Eckler, Columbus, OH, Richard E. May,Hunton & Williams, Washington, DC, James P. Holden (briefed), Susan H. Serling (briefed), Arthur L. Bailey (argued and briefed), Jean Male Baxley (briefed), Steptoe & Johnson, Washington, DC, for Plaintiffs-Appellants., Bernard J. Long (briefed), Dow, Lohnes & Albertson, Washington, DC, Raj Madan (briefed), Richard C. Stark (briefed), Sheri A. Dillon, John B. Magee (briefed), Gerald Goldman (briefed), McKee Nelson LLP, Washington, DC, for Amici Curiae.

  • For Appellees:
  • Dennis M. Donohue (argued and briefed), Richard Farber (briefed), United States Department of Justice, Appellate Section Tax Division, Washington, DC, James D. Hill (briefed), Internal Revenue Service, Office of Chief Counsel, Cincinnati, OH, Alex E. Sadler (briefed), United States Department of Justice, Tax Division, Washington, DC, for Defendant-Appellee.