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Cerand & Co. v. Commissioner of Internal Revenue Service

Tax court's order of deficiency, based on its conclusion that payments plaintiff made to three of its sister corporations were intended to be capital contributions rather than loans, remanded because tax court failed to consider that the taxpayer, over several years, treated as taxable interest income monies it received from its sister corporations.

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Argued December 4, 2000

Cerand & Co., Inc. (Cerand) appeals from a judgment of the tax court predicated upon that court’s conclusion that payments Cerand made to three of its sister corporations were intended to be capital contributions rather than loans. We hold that the tax court erred in failing to consider the fact seemingly most probative of the proper classification of the payments – that the taxpayer over several years treated as taxable interest income more than $175,000 it received from its sister corporations. Accordingly, we remand this matter to the tax court for further consideration.

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