Lehigh v. R. Co. v. Commissioner
United States Tax Court
1. The petitioner owned certain railroad property in the State of New Jersey, on which the state imposed a tax for each of the years 1932-1940. In each year the petitioner paid, before the due date, an amount of the tax imposed for that year, which it admitted to be due, and contested the unpaid balance in the courts.
Read the full summary
1. The petitioner owned certain railroad property in the State of New Jersey, on which the state imposed a tax for each of the years 1932-1940. In each year the petitioner paid, before the due date, an amount of the tax imposed for that year, which it admitted to be due, and contested the unpaid balance in the courts. Held, the amount unpaid and then in controversy accrued in the respective years when the litigation was terminated either by final action of the court or by discontinuance of the appeals. 2. During the progress of the litigation the petitioner paid additional amounts to the…
1Opinion of the Court
OPINION.
HaRbon, Judge:
The first question presented stems from the respondent’s disallowance of certain deductions from income of taxes imposed by the State of New Jersey, claimed by petitioner in the taxable years, and concerns the years in which such taxes, and the interest on the unpaid portion thereof, may be properly accrued.
There is no question here as to the total amount of the state taxes assessed, the amounts paid before the due date, the amount of the unpaid portion, the dates and amounts of subsequent payments, or the amounts currently deducted by petitioner in its income tax…
2Cases cited22 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Brown v. HelveringSupreme Court of the United States · 1934
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
17 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Lewyt Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Fifth Ave. Coach Lines,Inc. v. CommissionerUnited States Tax Court · 1959
- Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
- H. E. Harman Coal Corp. v. CommissionerUnited States Tax Court · 1951
- Lewyt Corp. v. CommissionerUnited States Tax Court · 1952
35 more not listed; retrieve them via the Exa API.