Grahm v. Commissioner
United States Tax Court
Petitioners acquired real property in Connecticut in November of 1948, agreeing to assume and pay all taxes levied or assessed upon the property after September 30, 1948. At the time they acquired title, real estate taxes had already become a lien on the property, and the former owner was personally liable therefor.
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Petitioners acquired real property in Connecticut in November of 1948, agreeing to assume and pay all taxes levied or assessed upon the property after September 30, 1948. At the time they acquired title, real estate taxes had already become a lien on the property, and the former owner was personally liable therefor. Held, petitioners may not deduct, as taxes paid or accrued, for the taxable year 1949, an amount paid by them in respect of such taxes, notwithstanding that pursuant to Connecticut law a vendee agreeing to pay such taxes becomes personally liable to the taxing authorities for the…
1Opinion of the Court
OPINION.
Raum, Judge:
Respondent has determined deficiencies in income taxes of petitioners as follows:
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The sole issue is whether petitioners are entitled to deduct under section 23 (c) of the Internal Revenue Code of 1939 pro rata parts of certain real estate taxes paid by a partnership consisting of the three wives. The deficiencies with respect to the taxable year 1949 are in dispute only insofar as they relate to the payment of such taxes, and the deficiencies with respect to the taxable year 1950 are not in dispute, except insofar as they may be affected by a decision with…
2Cases cited7 opinions
- Magruder v. SuppleeSupreme Court of the United States · 1942
- Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949
- Lifson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1938
- State Ex Rel. Pettigrew v. ThompsonSupreme Court of Connecticut · 1948
- Falk Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1932
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Godfrey v. CommissionerUnited States Tax Court · 1963
- Mel Dar Corp. v. CommissionerUnited States Tax Court · 1960
- Grahm v. CommissionerUnited States Tax Court · 1956