Park v. Commissioner
United States Board of Tax Appeals
DEDUCTION - INTEREST - INDEBTEDNESS. - Interest on a collateral note under seal given by a man in Pennsylvania to his wife is, under the laws of that state, interest on an enforceable indebtedness and is deductible for income tax purposes.
1Opinion of the Court
OPINION.
Murdock:
The Commissioner determined deficiencies in income tax of $2,731.40, $2,508.57, and $2,772.67 for 1932, 1933, and 1934. The Commissioner, in determining the deficiency for each year, dis*1119allowed a deduction of $9,000 claimed as interest paid on a note to tbe petitioner’s wife. The correctness of this action is the only issue not settled by agreement. The facts were stipulated and are found as stipulated.
The petitioner made, executed, and delivered his collateral demand note for $150,000 to his wife in Pennsylvania on December 14, 1923. The note bore interest at 6 percent. The…
2Cases cited8 opinions
- Erie Railroad v. TompkinsSupreme Court of the United States · 1938
- Poe v. SeabornSupreme Court of the United States · 1930
- Storm v. United StatesSupreme Court of the United States · 1877
- Killeen's EstateSupreme Court of Pennsylvania · 1932
- Yard v. PattonSupreme Court of Pennsylvania · 1850
3 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Santa Anita Consol., Inc. v. CommissionerUnited States Tax Court · 1968
- Stanton v. CommissionerUnited States Tax Court · 1960
- Commissioner of Internal Revenue v. ParkCourt of Appeals for the Third Circuit · 1940
- Jordan v. CommissionerUnited States Tax Court · 1973
- First Nat'l Co. v. CommissionerUnited States Tax Court · 1959
16 more not listed; retrieve them via the Exa API.