Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• affirming disallowance of interest deductions where debt was incurred solely for its anticipated tax consequences
• affirming disallowance of interest deductions where debt was incurred solely for its anticipated tax consequences
• requiring transaction “to have purpose, substance, or utility apart from their anticipated tax consequences” for deduction of interest payments under the 1954 Internal Revenue Code
• \The deduction is proper if there is some substance to the loan arrangement beyond the taxpayer's desire to secure the deduction.\
• \ Section 163(a) does not 'intend' that taxpayers should be permitted deductions for interest paid on debts that were entered into solely in order to obtain a deduction.\
• deduction for interest paid not available for transactions “that can not with reason be said to have purpose, substance, or utility apart from their anticipated tax consequences”

Source: CourtListener parenthetical corpus (CC0).