Oklahoma High School Athletic Association of State of Oklahoma v. Bray

This is a typical "thin corporation" case. The question is whether payments by a corporation to holders of its debenture notes are interest and for federal income tax purposes deductible under § 163(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 163(a). The District Director of Internal Revenue ruled that the payments were dividends rather than interest and assessed a deficiency which the corporation paid and sued to recover. The trial court sustained the Director and dismissed the action.