Estate of Stamos v. Commissioner
United States Tax Court
On their joint Federal income tax return for 1963, the taxpayers elected to capitalize certain tax and interest payments pursuant to sec. 266, I.R.C. 1954, and the regulations promulgated thereunder.
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On their joint Federal income tax return for 1963, the taxpayers elected to capitalize certain tax and interest payments pursuant to sec. 266, I.R.C. 1954, and the regulations promulgated thereunder. After the Commissioner subsequently determined that the taxpayers were not entitled to certain unrelated deductions which they had claimed on their 1963 return and consequently increased their taxable income from a loss of $ 1.26 to taxable income of $ 4,855.48, the taxpayers attempted to revoke their election and instead deduct the tax and interest payments in 1963. Held, the taxpayers' initial…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined deficiencies in the income tax of George and Evelyn J. Stamos (the taxpayers) in the amounts of $988.20 and $505.64 for tbe calendar years 1963 and 1964. Since tbe 1964 determination bas not been contested, only tbe deficiency determined witb respect to 1963 is before us. Tbe sole issue remaining for decision is wbetber the taxpayers may revoke tbeir prior timely election to capitalize certain interest and real property tax payments and 'instead deduct those payments in computing their 1963 income tax. Tbe case was submitted under Eule 30 on a…
2Cases cited39 opinions
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Pollack v. CommissionerUnited States Tax Court · 1966
- Hertz Corp. v. United StatesSupreme Court of the United States · 1960
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3Cited by29 opinions
- Taylor v. CommissionerUnited States Tax Court · 1977
- Dougherty v. CommissionerUnited States Tax Court · 1973
- Silver Queen Motel v. CommissionerUnited States Tax Court · 1971
- Grynberg v. CommissionerUnited States Tax Court · 1984
- Branum v. CommissionerCourt of Appeals for the Fifth Circuit · 1994
24 more not listed; retrieve them via the Exa API.