Legal Opinion

Robbins Tire & Rubber Co. v. Commissioner

United States Tax Court

Decided June 12, 1969No. Docket No. 2287-67Published

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…

2Cases cited21 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Commissioner v. CulbertsonSupreme Court of the United States · 1949
  3. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  4. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  5. Amos v. Comm'rUnited States Tax Court · 1966

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