Maxcy v. Commissioner
United States Tax Court
Interest accrued and paid on deficiencies in personal income tax is not deductible as a business deduction from gross income for the purpose of computing a net operating loss of the taxpayer's business under section 122, I. R. C. 1939.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
The respondent determined a deficiency in petitioner’s income tax for the taxable year ended June 30, 1951, in the amount of $2,221, with a penalty of $383.35 under section 294 (d) (2), Internal Revenue Code of 1939. The penalty and certain minor adjustments are not contested. The parties stipulate that the issue between them “is whether petitioner could properly deduct the sum of $8,707.03, representing interest accrued on personal income tax deficiencies for the fiscal years 1944, 1945, 1946, and 1951, as a business deduction from gross income in the fiscal year…
2Cited by11 opinions
- Polk v. CommissionerUnited States Tax Court · 1958
- Commissioner of Internal Revenue v. James J. Standing and Marie S. StandingCourt of Appeals for the Fourth Circuit · 1958
- Redlark v. Comm'rUnited States Tax Court · 1996
- Reise v. CommissionerUnited States Tax Court · 1961
- Estate of Broadhead v. CommissionerUnited States Tax Court · 1966
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