In the taxpayer’s appeal from a tax court’s ruling that the taxpayer could not deduct payments for cash distribution redemptive dividends, the order is affirmed where, because 26 U.S.C. section 404(k) did not provide for a deduction-for-dividends-paid under 26 U.S.C. section 561, the taxpayer did not have a “deduction for dividends paid (within the meaning of section 561)” needed to satisfy the exception in 26 U.S.C. section 162(k)(A)(iii).

Read Nestle Purina Petcare Co. v. Comm’r. of Int’l. Rev., No. 09-1381

Appellate Information

Submitted: December 15, 2009

Filed: February 9, 2010

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