Legal Opinion

Robbins Tire & Rubber Co. v. Commissioner

United States Tax Court

Decided November 24, 1969No. Docket No. 2287-67Published

1. Held, petitioner's payments to the district director during that part of its taxable year preceding its submission of offers in compromise were credited pursuant to the offers upon their acceptance by the Government. 2. Held, further, the discharge of petitioner's interest liabilities by its transferee's payment does not entitle petitioner to an interest deduction. 3. Held, further, this Court has no jurisdiction to determine whether a refund of the overpayment of tax…

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1. Held, petitioner's payments to the district director during that part of its taxable year preceding its submission of offers in compromise were credited pursuant to the offers upon their acceptance by the Government. 2. Held, further, the discharge of petitioner's interest liabilities by its transferee's payment does not entitle petitioner to an interest deduction. 3. Held, further, this Court has no jurisdiction to determine whether a refund of the overpayment of tax made by petitioner is barred. Sec. 6512(b)(1), I.R.C. 1954.

1Opinion of the Court

Robbins Tire and Rubber Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Robbins Tire & Rubber Co. v. Commissioner

Docket No. 2287-67

United States Tax Court

53 T.C. 275; 1969 U.S. Tax Ct. LEXIS 19;

November 24, 1969, Filed

Decision will be entered under Rule 50.

1. Held, petitioner's payments to the district director during that part of its taxable year preceding its submission of offers in compromise were credited pursuant to the offers upon their acceptance by the Government.

2. Held, further, the discharge of petitioner's interest liabilities by its transferee's payment…

2Cases cited13 opinions

  1. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  2. United States Ex Rel. Girard Trust Co. v. HelveringSupreme Court of the United States · 1937
  3. Guardian Investment Corporation v. Robert L. Phinney, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
  4. Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
  5. Herbert v. RiddellDistrict Court, S.D. California · 1952

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