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CROUCH v. UNITED STATES

No. 81-1196.

692 F.2d 97 (1982)

John D. CROUCH, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Tenth Circuit.

October 25, 1982.

Attorney(s) appearing for the Case

Charles W. German of Stinson, Mag & Fizzell, Kansas City, Mo., for plaintiff-appellant.

Michael L. Paup, Washington, D.C. (John F. Murray, Acting Asst. Atty. Gen., Richard W. Perkins and John A. Dudeck, Jr., Attys., Tax Div., Dept. of Justice, Washington, D.C., of counsel, James P. Buchele, U.S. Atty., Topeka, Kan., with him on the brief), for defendant-appellee.

Before DOYLE and LOGAN, Circuit Judges, and BOHANON, District Judge.

LOGAN, Circuit Judge.

John D. Crouch appeals from the district court's judgment denying his claim for a refund of taxes paid to the United States. 509 F.Supp. 727. The issues on appeal are whether the trial court correctly held (1) the taxpayer is not entitled to an interest expense deduction for amounts he paid on a loan made to his wholly owned corporation, and (2) the corporation's election to be taxed as a small business corporation...

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