Koppers Co. v. Commissioner
United States Tax Court
1. Petitioner was liable as transferee for the income tax deficiencies and the interest thereon of certain liquidated and dissolved corporations. In 1938, a year subsequent to those in which the liquidations occurred, the petitioner agreed to and paid such deficiencies in tax and interest.
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1. Petitioner was liable as transferee for the income tax deficiencies and the interest thereon of certain liquidated and dissolved corporations. In 1938, a year subsequent to those in which the liquidations occurred, the petitioner agreed to and paid such deficiencies in tax and interest. Held, that none of the interest which accrued on the deficiencies from their due date to the date the property of the transferors was received by petitioner is deductible by petitioner as interest under section 23 (b) of the Revenue Act of 1938. Held, further, that the interest which accrued thereafter is…
1Opinion of the Court
OPINION.
Leech, Judge:
The petitioner is a Delaware corporation, and has its principal office in Pittsburgh, Pennsylvania. Its return for the year 1938 was filed with the collector of internal revenue in that city. The respondent has determined against it a deficiency in income tax for the year 1938 in the amount of $15,112.55. The petitioner claims an overpayment of $19,500.
All of the facts have been stipulated and are found as stipulated.
Issue I.
During the taxable year the petitioner agreed to pay and paid $233,-833.42 representing deficiencies in income tax with interest thereon due and…
2Cases cited2 opinions
- Kieselbach v. CommissionerSupreme Court of the United States · 1943
- Brown v. CommissionerUnited States Tax Court · 1942
3Cited by46 opinions
- Koppers Coal Co. v. CommissionerUnited States Tax Court · 1946
- Lowy v. CommissionerUnited States Tax Court · 1960
- Jergens v. CommissionerUnited States Tax Court · 1951
- Commissioner of Internal Revenue v. BreyerCourt of Appeals for the Third Circuit · 1945
- Forrester v. CommissionerUnited States Tax Court · 1945
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