Roemer v. Commissioner
United States Tax Court
In five separate transactions petitioners paid certain amounts which were designated as prepaid interest. Held, Rev. Rul. 68-643, 1968-2 C.B. 76, by its terms, applies retroactively to an interest prepayment sufficient to pay 3 2/3 years' interest where such amount may be, and is applied, at the sole discretion of the lender, to satisfy interest obligations arising during a period in excess of 5 years from the prepayment date.
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In five separate transactions petitioners paid certain amounts which were designated as prepaid interest. Held, Rev. Rul. 68-643, 1968-2 C.B. 76, by its terms, applies retroactively to an interest prepayment sufficient to pay 3 2/3 years' interest where such amount may be, and is applied, at the sole discretion of the lender, to satisfy interest obligations arising during a period in excess of 5 years from the prepayment date. Held, further, Rev. Rul. 68-643 applies retroactively to the entire amount of an interest prepayment for an indefinite period where there is at least a probability that…
1Opinion of the Court
Forrester, Judge:
In these consolidated cases, respondent has determined deficiencies in petitioners’ Federal income taxes as follows:
Petitioners Taxable year Amount
Paul F. Roemer, Jr., and Marcia E. Roemer, docket No. 3837-74. 1968 $20,817.55
1969 4,837.21
Robert S. Brickell and Roberta A. Brickell, docket No. 3838-74. 1968 23,727.94
1969 90.67
Harry T. Holgerson, Jr., and Mary E. Holgerson, docket No. 3915-74. 1964 1,883.05
1965 133,754.58
1966 221,513.25
1967 385,666.48
1968 428,111.80
1969 207,583.51
Concessions having been made, there are two issues remaining for our decision: (1) Whether certain…
2Cases cited16 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Mayerson v. CommissionerUnited States Tax Court · 1966
- Goldstein v. CommissionerUnited States Tax Court · 1965
- Sandor v. CommissionerUnited States Tax Court · 1974
11 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Schubel v. CommissionerUnited States Tax Court · 1981
- Harry T. Holgerson, Jr. And Mary Holgerson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1981
- Roemer v. CommissionerUnited States Tax Court · 1977
- Sanborn v. CommissionerUnited States Tax Court · 1983
- Schubel v. CommissionerUnited States Tax Court · 1981