Louisiana & A. R. Co. v. Commissioner
United States Board of Tax Appeals
The Board has jurisdiction of a proceeding brought by a transferee for the redetermination of its liability for interest on a deficiency in tax of the transferor. So held where the deficiency had already been determined in a proceeding brought by the transferor and paid.
1Opinion of the Court
OPINION.
Sternhagen :
The question presented at the outset is whether the Board has jurisdiction of this proceeding, since it involves no issue as to the deficiency of the transferor or the petitioner’s liability therefor, that deficiency having already been definitively determined and paid, but only an issue as to the petitioner’s liability for the interest on such deficiency. While the evidence, all of which is stipulated, does not show how the amount of interest was computed, it is nevertheless a fixed amount, and it seems to approximate simple interest at 6 percent for the period of more…
2Cases cited10 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Cappellini v. CommissionerUnited States Board of Tax Appeals · 1929
- Capital Bldg. & Loan Asso. v. CommissionerUnited States Board of Tax Appeals · 1931
- Costanzo v. CommissionerUnited States Board of Tax Appeals · 1929
- Gideon-Anderson Co. v. CommissionerUnited States Board of Tax Appeals · 1930
5 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Lowy v. CommissionerUnited States Tax Court · 1960
- Transport Manufacturing & Equipment Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 1970
- Transport Manufacturing & Equipment Company, a Delaware Corporation, Transferee v. Commissioner of Internal Revenue, Transport Manufacturing & Equipment Company, an Illinois Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1970
- Benson v. CommissionerUnited States Tax Court · 1985
- Estate of McGlue v. CommissionerUnited States Tax Court · 1943
6 more not listed; retrieve them via the Exa API.