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SECURITY FINANCE & LOAN COMPANY v. KOEHLER

No. W-2174.

210 F.Supp. 603 (1962)

SECURITY FINANCE & LOAN COMPANY, Plaintiff, v. Gus F. KOEHLER, District Director of Internal Revenue, Defendant.

United States District Court D. Kansas.

September 21, 1962.

Attorney(s) appearing for the Case

R. R. Mitchell, Gould, Mitchell & Smith, Dodge City, Kan., for plaintiff.

George A. Hrdlicka, Dept. of Justice, Washington, D. C., for defendant; Louis F. Oberdorfer, Asst. Atty. Gen., Edward S. Smith, Charles W. Mehaffy, Alphonsus C. Murphy, Attys., Dept. of Justice, Washington, D. C. and Newell A. George, U. S. Atty., Topeka, Kan., and Robert M. Green, Asst. U. S. Atty., Wichita, Kan., were with George A. Hrdlicka, Washington, D. C., on brief.

ARTHUR J. STANLEY, Jr., Chief Judge.

The plaintiff, Security Finance and Loan Company, is seeking recovery of $8,295.30, plus interest, paid by the plaintiff after deficiency assessment against it for the years 1955, 1956, and 1957. The deficiency resulted from the disallowance by the Commissioner of Internal Revenue of payments made by the plaintiff to its stockholders and their relatives, which were designated as interest and deducted as business expense on the...

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