United States DC Circuit
CERAND & CO., INC. v. COMM'R OF INTERNAL REVENUE SERV., 99-1252
In determining whether fund transfers between sister corporations were loans or captial contributions, tax court must consider evidence that the corporation which loaned/invested the funds declared repayments as interest income, rather than as capital gain.
Appellate Information
- Argued 12/04/2000
- Decided 07/06/2001
- Published 07/06/2001
Judges
- GINSBURG, Circuit Judge:, Before: WILLIAMS, GINSBURG and GARLAND, Circuit Judges.
Court
- United States DC Circuit
Counsel
- For Appellant:
- Michael S. Fried argued the cause and filed the brief for appellant.
- For Appellees:
- Joel McElvain, Attorney, U.S. Department of Justice, argued the cause for appellee. With him on the brief was Kenneth L. Greene, Attorney. David E. Carmack, Attorney, entered an appearance.