Cohen v. Commissioner
United States Tax Court
Accounting -- Accrual -- Interest -- Payment Doubtful. -- A taxpayer regularly using an accrual method of accounting may deduct accrued interest even though not in good financial condition.
1Opinion of the Court
OPINION.
MuRdock, Judge:
The evidence shows that the books of the petitioner were regularly kept on an accrual method of accounting at all times material hereto and that the use of that method clearly reflects his annual income. The evidence also shows that the amount of the interest accrued on his books for the taxable years was a legal obligation. The determination of the Commissioner was erroneous insofar as it disallowed the deductions claimed for interest on the returns. The Commissioner had no right under the law to disregard the accrual method of bookkeeping employed by the petitioner…
2Cases cited8 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Helvering v. Russian Finance & Construction CorporationCourt of Appeals for the Second Circuit · 1935
- Pearlman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1946
- Zimmerman Steel Co. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1942
- Pearlman v. CommissionerUnited States Tax Court · 1944
3 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Taube v. CommissionerUnited States Tax Court · 1987
- Fahs v. MartinCourt of Appeals for the Fifth Circuit · 1955
- Tampa & G. C. R. Co. v. CommissionerUnited States Tax Court · 1971
- Sartin v. United StatesUnited States Court of Claims · 1984
- Fahs v. MartinCourt of Appeals for the Fifth Circuit · 1955
12 more not listed; retrieve them via the Exa API.