RICHARD CHACE AND FRANCES L. CHACE, HIS WIFE, PLAINTIFFS-APPELLANTS,
v.
UNITED STATES OF AMERICA, DEFENDANT-APPELLEE

5th Cir. | 1970-02-17
No. 28601
Before WISDOM, COLEMAN, and SIMPSON, Circuit Judges.
422 F.2d 292 Court of Appeals for the Fifth Circuit (1970) Positive Treatment
Cited by 8 cases

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Holding

The court affirmed the district court's judgment regarding the deductibility of rental payments.


Facts & Procedural History

Taxpayers sued for a refund of income taxes for 1963-1965. The issue was the deductibility of rental payments made by Dr. Chace for a building he prev…

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Opinion of the Court
PER CURIAM:

PER CURIAM:

Pursuant to Rule 18 of the Rules of this Court, we have concluded on the merits that this case is of such character as not to justify oral argument and have directed the clerk to place the case on the Summary Calendar and to notify the parties in writing. See Murphy v. Houma Well Service, 5 Cir., 1969, 409 F. 2d 804, Part I; and Huth v. Southern Pacific Company, 5 Cir., 1969, 417 F. 2d 526, Part I.

In this case the taxpayers sued for the refund of income taxes, and interest, assessed and collected for the years 1963, 1964, and 1965. At issue is the deductibility of certain rental payments made by Dr. Chace for the use of a building previously owned by him and thereafter placed in trust for ten years. The factual details are reported in the opinion of the District Court, 303 F. Supp. 513 (M.D., Fla., 1969) 1

For the reasons there appearing and upon the authorities there cited, we affirm the judgment of the District Court.

See, in particular, Furman v. Commissioner of Internal Revenue, 5 Cir., 1967, 381 F. 2d 22 and Van Zandt v. Commissioner of Internal Revenue, 5 Cir., 1965, 341 F. 2d 440, cert. denied, 382 U.S. 814, 86 S.Ct. 32, 15 L.Ed.2d 62.

Affirmed.

. The trust involved was of the so-called “Clifford Type”. See Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed. 788; and Internal Revenue Code of 1954, Secs. 671-678 (26 U.S.C. 1964 Ed., Secs. 671-678).


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