Perkins v. Commissioner
United States Tax Court
R issued a notice of deficiency to P on Dec. 19, 1983, for the taxable year 1980. On Dec. 30, 1983, P forwarded a check to R with the designation that the remittance be credited to accrued interest on the 1980 deficiency. On his 1983 return, P deducted the amount paid as a payment of interest and R disallowed the deduction.
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R issued a notice of deficiency to P on Dec. 19, 1983, for the taxable year 1980. On Dec. 30, 1983, P forwarded a check to R with the designation that the remittance be credited to accrued interest on the 1980 deficiency. On his 1983 return, P deducted the amount paid as a payment of interest and R disallowed the deduction. In response to a notice of deficiency issued for the taxable year 1983, P filed a petition alleging entitlement to the interest deduction claimed on his 1983 return. The parties filed cross-motions for summary judgment on the issue of whether P was entitled to claim an…
1Opinion of the Court
OPINION
Gerber, Judge:
This case was assigned to Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code of 1986 and Rule 180 et seq. of the Tax Court Rules of Practice and Procedure.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge:
This case is before the Court on cross-motions for summary judgment. The question to be decided is whether an amount paid by petitioner in 1983 on a deficiency determined by respondent for the…
2Cases cited23 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Naftel v. CommissionerUnited States Tax Court · 1985
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Rosenman v. United StatesSupreme Court of the United States · 1945
- Shiosaki v. CommissionerUnited States Tax Court · 1974
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3Cited by12 opinions
- Horton Homes, Inc., N.D. Horton, Jr., Jacqueline P. Horton, N.D. Horton, Sr. And Maude Horton v. United StatesCourt of Appeals for the Eleventh Circuit · 1991
- Risman v. CommissionerUnited States Tax Court · 1993
- Hongsermeier v. CommissionerCourt of Appeals for the Ninth Circuit · 2010
- Humberson v. CommissionerUnited States Tax Court · 1995
- Amann v. Comm. IRSCourt of Appeals for the First Circuit · 1994
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