Liberty Loan Corporation v. United States

498 F.2d 225
CourtCourt of Appeals for the Eighth Circuit
DecidedJuly 19, 1974
Docket73-1389
StatusPublished
Cited by14 cases

This text of 498 F.2d 225 (Liberty Loan Corporation v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Liberty Loan Corporation v. United States, 498 F.2d 225 (8th Cir. 1974).

Opinions

LAY, Circuit Judge.

The United States appeals from a judgment of the district court granting Liberty Loan Corporation (hereinafter taxpayer) a refund of $246,292.28 plus interest for 1961 income taxes alleged to have been wrongfully assessed and paid. The trial court’s opinion is reported at 359 F.Supp. 158 (E.D.Mo.1973). We reverse the judgment for the taxpayer and remand with directions to enter judgment in favor of the government.

The fundamental issue is whether the Commissioner of Internal Revenue properly exercised his discretion under 26 U.S.C. § 482 1 and the regulations promulgated thereunder in allocating to taxpayer the amount of $473,639 as interest income from certain of its wholly-owned subsidiaries.

Taxpayer is engaged in the consumer finance business, operating through 40 branch offices and 399 subsidiaries in several states. In 1961, taxpayer borrowed substantial sums which it then loaned to its 399 subsidiaries. The subsidiaries in turn loaned the monies to consumers. This procedure of borrowing by the parent was employed because of the parent’s higher credit rating, which enabled it to borrow at a lower rate of interest than would have been available to the subsidiaries acting independently.2 In 1961, taxpayer was [227]*227able to borrow the amount involved, over $110,547,000, at an effective interest rate of 5.55%. The ultimate consumers were charged considerably higher interest rates by the subsidiaries.3

Rather than charge each subsidiary 5.55% interest, taxpayer charged its solvent companies 5.75%, while its 55 insolvent enterprises were charged little or no interest.4 This system resulted in interest income to taxpayer just sufficient to cover its own interest expense on the total amount borrowed, i. e., 5.55%.

The Commissioner determined that taxpayer’s 1961 income had not been clearly reflected due to the no-interest loans.5 Acting pursuant to § 482 and the regulations thereunder, the Commissioner therefore increased taxpayer’s income to reflect interest payments of 5% from the insolvent subsidiaries.6 No adjustment was made to the 5.75% interest income received from the solvent subsidiaries.

Upon Liberty Loan’s suit for a refund, the district court found no distortion in taxpayer’s income, since taxpayer had received the actual costs of its borrowing from the overall group of subsidiaries. Hence, the court held that § 482 and its regulations had been improperly applied. The court recognized that the income of the subsidiaries had been distorted; however, it held the Commissioner erred in attempting to adjust the income of the taxpayer, rather than unscrambling the distortion among the subsidiaries.

The regulations under § 482 specifically require that the method of allocating and apportioning income “shall be determined with reference to the substance of the particular transactions . . . .” Regs. § 1.482-1 (d)(1) (emphasis added). We find the “group loan” theory of the trial court ignores the actual substance of the transactions under scrutiny here. It is clear that the loans by the taxpayer were not made to a single entity or group. The facts stipulated show that the loans were made individually to each subsidiary; the interest rates charged the individual subsidiaries ranged from 0 to 5.75%, depending on the capital status of each company; each subsidiary carried on its balance sheets a note payable to its parent; and each subsidiary filed a separate income tax return, reflecting the individual loan from the parent. Although the parent, for admittedly sound business reasons, may have borrowed a lump sum, nevertheless when it came to relending the monies to the subsidiaries, it is evident that each loan was a separate transaction requiring independent scrutiny by the Commissioner.

[228]*228The individual nature of taxpayer’s loans to its controlled interests is not altered in any way by the references to “group borrowing” contained in Paragraph 3 of the stipulation. As the government notes in its brief:

This label is in itself meaningless; here it can signify no more than that the assets of the entire group of corporations were made subject to the lender’s debt claim in order to achieve more favorable interest rates. But this is a, fortiori true of any loan to a parent corporation since the assets of its subsidiaries can be reached by its creditors. Hence, the parent is likely to be in a better credit position than the individual subsidiaries.

Equally unsupported by the facts is taxpayer’s argument that the solvent subsidiaries, rather than the parent, were actually the creditors of the insolvent concerns to the extent the insolvent companies failed to pay their full share of the interest costs. There is no evidence that the insolvent subsidiaries had any obligation to pay the “gain” subsidiaries any amounts whatsoever. The balance sheets of the gain subsidiaries do not reflect any amounts due from the “loss” subsidiaries. Particularly noteworthy in this regard is the fact that some of the insolvent subsidiaries paid the parent 5.75% interest for six months of the year. See note 4, supra. If the taxpayer’s theory were true, these amounts would have been paid to the gain subsidiaries, not to the parent.

Moreover, the stipulated fact that the gain subsidiaries paid 5.75% interest, while the loss subsidiaries paid little or no interest, is totally inconsistent with taxpayer’s assertion that all of the subsidiaries actually paid 5.55%, with the gain subsidiaries loaning the necessary interest amounts to the loss subsidiaries.

Viewed as a number of independent transactions, it is readily apparent that the no-interest loans to the insolvent subsidiaries distorted taxpayer’s 1961 taxable income. As the Second Circuit has observed, in construing § 482:

The instant loans without interest are obviously not at arm’s length, since no unrelated parties would loan such large sums without interest. The allocation of the interest income to taxpayers was necessary in order to properly reflect their taxable incomes.

B. Forman Co. v. Commissioner, 453 F.2d 1144, 1156 (2d Cir.), cert. denied, 407 U.S. 934, 92 S.Ct. 2458, 32 L.Ed.2d 817, rehearing denied, 409 U.S. 899, 93 S.Ct. 102, 34 L.Ed.2d 158 (1972).

We note also that even if one were to accept the “group loan” premise of the trial court, there is nevertheless a distortion in taxpayer’s income. As the trial court recognized:

Low or no income subsidiaries would have significantly less use for an interest expense deduction, whereas a subsidiary corporation in a surtax bracket would be able to utilize the deduction against higher tax rates. The internal apportionment undoubtedly led to substantial overall savings in taxes to the group, taken as a whole. (emphasis added).

359 F.Supp. at 162-163.

We think it obvious that any savings in taxes realized by the subsidiaries has the effect of increasing the parent’s net worth and hence distorting its true income.

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