Robbins Tire & Rubber Co. v. Commissioner
United States Tax Court
Petitioner, an accrual basis taxpayer, and respondent entered into an agreement settling prior tax liabilities. During its taxable year ending Sept. 30, 1964, petitioner made certain payments pursuant to the terms of the settlement, in an amount less than the total of the compromised taxes and penalties.
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Petitioner, an accrual basis taxpayer, and respondent entered into an agreement settling prior tax liabilities. During its taxable year ending Sept. 30, 1964, petitioner made certain payments pursuant to the terms of the settlement, in an amount less than the total of the compromised taxes and penalties. Held: In accordance with Rev. Rul. 58-239, 1958-1 C.B. 94, the payments are to be applied against the taxes, penalties, and interest, in that order, due for the earliest year, then to taxes, penalties, and interest, in that order, due for each succeeding year, until the payments are absorbed.…
1Opinion of the Court
* Robbins Tire and Rubber Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Robbins Tire & Rubber Co. v. Commissioner
Docket No. 2287-67
United States Tax Court
52 T.C. 420; 1969 U.S. Tax Ct. LEXIS 115;
June 12, 1969, Filed
Decision will be entered under Rule 50.
Petitioner, an accrual basis taxpayer, and respondent entered into an agreement settling prior tax liabilities. During its taxable year ending Sept. 30, 1964, petitioner made certain payments pursuant to the terms of the settlement, in an amount less than the total of the compromised taxes and penalties. Held: In…
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