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Tax Law - In Re Kroy (Europe) Limited: Whether A Corporation May Amortize And Deduct Loan Fees Incurred In Financing A Stock Redemption, Robert G. Lorndale Jr.
Tax Law - In Re Kroy (Europe) Limited: Whether A Corporation May Amortize And Deduct Loan Fees Incurred In Financing A Stock Redemption, Robert G. Lorndale Jr.
Golden Gate University Law Review
In In re Kroy (Europe) Limited,l the Ninth Circuit held that a corporation could amortize and deduct fees which it incurred in borrowing funds used to redeem stock under §162(a) of the Internal Revenue Code. Section 162(a) allows a corporation to deduct ordinary and necessary business expenses. Kroy required the court to decide whether §162(k) of the Internal Revenue Code, an exception to §162(a), applied to these fees and would preclude their deduction. Section 162(k) disallows deduction of any expenses incurred "in connection with" a stock redemption. The Ninth Circuit determined that §162(k) did not apply to the fees because …
Taxation, Robert C. Gabrielski, Robert Michael Fanucci
Taxation, Robert C. Gabrielski, Robert Michael Fanucci
Golden Gate University Law Review
No abstract provided.