Legal Opinion

La Croix v. Commissioner

United States Tax Court

Decided January 17, 1974No. Docket Nos. 5128-71, 5129-71, 5130-71, 5133-71, 5134-71, 5135-71, 5138-71, 5139-71, 5140-71, 5141-71, 5142-71, 5143-71, 5144-71, 5145-71, 5154-71, 5218-71, 7886-71Published

1. The petitioners' limited partnership purchased an office building and made a "prepayment of interest" in the amount of $ 250,000 which the partnership claimed as an interest deduction in the year of payment.

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1. The petitioners' limited partnership purchased an office building and made a "prepayment of interest" in the amount of $ 250,000 which the partnership claimed as an interest deduction in the year of payment. The sales contract called for additional periodic interest and principal payments and required at some point the crediting against principal due of "interest paid in advance" or "prepaid interest" in the amount of $ 250,000. Held: The petitioners' partnership is not entitled to an interest deduction under sec. 163(a) for this $ 250,000 payment. This payment was in effect a deposit or…

1Opinion of the Court

Kenneth D. LaCroix and Rhetta S. LaCroix, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

La Croix v. Commissioner

Docket Nos. 5128-71, 5129-71, 5130-71, 5133-71, 5134-71, 5135-71, 5138-71, 5139-71, 5140-71, 5141-71, 5142-71, 5143-71, 5144-71, 5145-71, 5154-71, 5218-71, 7886-71

United States Tax Court

61 T.C. 471; 1974 U.S. Tax Ct. LEXIS 168; 61 T.C. No. 53;

January 17, 1974, Filed

Decisions will be entered for the respondent.

1. The petitioners' limited partnership purchased an office building and made a "prepayment of interest" in the amount of $ 250,000 which the partnership…

2Cases cited29 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  4. Dobson v. CommissionerSupreme Court of the United States · 1944
  5. Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920

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