Court of Appeals for the Fifth Circuit November 6, 1980, 79-2292 (Lx Cattle Company v. United States)

THORNBERRY, Circuit Judge:

This appeal from the district court’s judgment in favor of the Internal Revenue Service raises the question whether appellant, a personal holding company during the years at issue, is entitled to a § 545(b)(1) deduction for the tax years 1968-70, even though appellant did not pay the income taxes giving rise to the deduction until 1971 and contested the payment in 1973.