Legal Opinion

Keith v. Commissioner

United States Tax Court

Decided March 31, 1961No. Docket No. 78006Published

1. Held: Amounts remitted by petitioner to district director with offer in compromise of assessed prior years' liability for tax, additions to tax, and interest, in which petitioner agreed that if offer rejected, the amounts deposited could be applied on the liability, and which remittances the district director deposited in special deposit account until claims rejected, do not constitute payments on the liability at the times remitted so as to entitle petitioner to a…

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1. Held: Amounts remitted by petitioner to district director with offer in compromise of assessed prior years' liability for tax, additions to tax, and interest, in which petitioner agreed that if offer rejected, the amounts deposited could be applied on the liability, and which remittances the district director deposited in special deposit account until claims rejected, do not constitute payments on the liability at the times remitted so as to entitle petitioner to a deduction for interest at that time. Under the circumstances remittances do not become payments until applied to the liability…

1Opinion of the Court

James F. Keith and Mabel S. Keith, Petitioners, v. Commissioner of Internal Revenue, Respondent

Keith v. Commissioner

Docket No. 78006

United States Tax Court

35 T.C. 1130; 1961 U.S. Tax Ct. LEXIS 181;

March 31, 1961, Filed

Decision will be entered for the respondent.

1. Held: Amounts remitted by petitioner to district director with offer in compromise of assessed prior years' liability for tax, additions to tax, and interest, in which petitioner agreed that if offer rejected, the amounts deposited could be applied on the liability, and which remittances the district director deposited in special…

2Cases cited17 opinions

  1. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  2. Rosenman v. United StatesSupreme Court of the United States · 1945
  3. Lewyt Corp. v. CommissionerSupreme Court of the United States · 1955
  4. National Bank of the Commonwealth v. Mechanics' National BankSupreme Court of the United States · 1877
  5. Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941

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