Arheit v. Commissioner
United States Tax Court
Sec. 23 (b) -- Deductibility of Interest: Year of Payment: Suspense Account Deposit. -- In 1952, prior to any formal determinations or assessments of deficiencies in income tax for the years 1945-1950, inclusive, petitioner made a remittance to a collector of estimated tax deficiencies and interest thereon up to the date of the remittance for the purpose of stopping the running of interest upon proposed deficiencies.
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Sec. 23 (b) -- Deductibility of Interest: Year of Payment: Suspense Account Deposit. -- In 1952, prior to any formal determinations or assessments of deficiencies in income tax for the years 1945-1950, inclusive, petitioner made a remittance to a collector of estimated tax deficiencies and interest thereon up to the date of the remittance for the purpose of stopping the running of interest upon proposed deficiencies. Petitioner's estimate of deficiencies was based upon information received informally from agents of the Commissioner about their reports recommending determinations of…
1Opinion of the Court
Fred J. Arheit and Gertrude E. Arheit, Petitioners, v. Commissioner of Internal Revenue, Respondent
Arheit v. Commissioner
Docket No. 63289
United States Tax Court
31 T.C. 46; 1958 U.S. Tax Ct. LEXIS 68;
October 10, 1958, Filed
Decision will be entered for the respondent.
Sec. 23 (b) -- Deductibility of Interest: Year of Payment: Suspense Account Deposit. -- In 1952, prior to any formal determinations or assessments of deficiencies in income tax for the years 1945-1950, inclusive, petitioner made a remittance to a collector of estimated tax deficiencies and interest thereon up to the date of the…
2Cases cited10 opinions
- Rosenman v. United StatesSupreme Court of the United States · 1945
- Lewyt Corp. v. CommissionerSupreme Court of the United States · 1955
- Lewyt Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- United States v. Dubuque Packing Company, a Corporation, Dubuque Packing Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1956
- Budd Company v. United StatesCourt of Appeals for the Third Circuit · 1957
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