Legal Opinion
Vidal Suriel v. Commissioner
United States Tax Court
Decided December 4, 2013No. 367-12Published
1Opinion of the Court
141 T.C. No. 16
UNITED STATES TAX COURT VIDAL SURIEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 367-12. Filed December 4, 2013. P’s wholly owned S corporation, V, claimed deductions for unpaid obligations, both principal and interest, owed into the Tobacco Master Settlement Agreement (MSA) fund, which is a qualified settlement fund under I.R.C. sec. 468B. R disallowed the deductions on the basis that economic performance did not occur until payment was actually made into the MSA fund, pursuant to sec. 1.468B- 3(c)(1), Income Tax Regs. Under I.R.C. sec. 1366 R made…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Fourco Glass Co. v. Transmirra Products Corp.Supreme Court of the United States · 1957
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