Armour v. Commissioner
United States Tax Court
1. Petitioner was liable as transferee for personal holding company surtax deficiencies and interest thereon of a liquidated and dissolved corporation. In 1940 petitioner paid the deficiencies and interest, all of which had accrued after the date of transfer. Held, the interest is deductible by petitioner under section 23 (b), Internal Revenue Code. Koppers Co., 3 T. C. 62; affd., 151 Fed.
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1. Petitioner was liable as transferee for personal holding company surtax deficiencies and interest thereon of a liquidated and dissolved corporation. In 1940 petitioner paid the deficiencies and interest, all of which had accrued after the date of transfer. Held, the interest is deductible by petitioner under section 23 (b), Internal Revenue Code. Koppers Co., 3 T. C. 62; affd., 151 Fed. (2d) 267, and Robert L. Smith, 6 T. C. 255, followed. 2. Petitioner paid $ 200 in miscellaneous legal fees in connection with the management, conservation, or maintenance of property held for the production…
1Opinion of the Court
OPINION.
Arundell, Judge:
In the taxable year the petitioner paid $11,966.63 as interest on a deficiency asserted against him as a transferee. The entire amount so paid accrued after the corporate property had been distributed by the transferor, and the petitioner seeks a deduction therefor under section 23 (b), Internal Revenue Code. The respondent has disallowed the deduction for the reason that the petitioner did not make a payment of interest on his personal obligation when he paid the collector the statutory interest on a deficiency in Federal personal holding company surtax assessed…
2Cases cited6 opinions
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
- Cammack v. CommissionerUnited States Tax Court · 1945
- Bingham v. CommissionerUnited States Tax Court · 1943
- Higgins v. CommissionerUnited States Tax Court · 1943
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Armour v. CommissionerUnited States Tax Court · 1946