Jergens v. Commissioner
United States Tax Court
1. Held: Petitioner, a cash basis taxpayer, made payments of of interest and expenses when the corporation, of which he was president, remitted checks to his creditors and charged petitioner's personal account with the amount paid, the charges being offset in the taxable year by credits to the account. 2. Held: Interest, accrued after the transfer on gift and income tax deficiencies determined against petitioner's transferor and for which petitioner was liable as transferee,…
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1. Held: Petitioner, a cash basis taxpayer, made payments of of interest and expenses when the corporation, of which he was president, remitted checks to his creditors and charged petitioner's personal account with the amount paid, the charges being offset in the taxable year by credits to the account. 2. Held: Interest, accrued after the transfer on gift and income tax deficiencies determined against petitioner's transferor and for which petitioner was liable as transferee, was deductible under section 23 (b), I. R. C. 3. Held: Attorney's fees and appraisal expenses incurred by taxpayer in…
1Opinion of the Court
OPINION.
Van Fossan, Judge:
Several issues are presented under the statutory provisions by petitioner’s claim for deductions. The respondent contends, at the outset, that the petitioner has not proved the fact of payment of the amounts he seeks to deduct. The payment of interest on the gift and income tax deficiencies and the expenses of the Tax Court and Florida litigation were made by checks drawn by the Jergens Company. The petitioner’s personal account was then charged with such amounts. The respondent argues that the petitioner must suffer a cash detriment before the deduction can be…
2Cases cited7 opinions
- Koppers Co. v. CommissionerUnited States Tax Court · 1944
- Moore v. CommissionerUnited States Tax Court · 1942
- Orange Securities Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1942
- Watson v. CommissionerUnited States Tax Court · 1947
- Commissioner of Internal Revenue v. BreyerCourt of Appeals for the Third Circuit · 1945
2 more not listed; retrieve them via the Exa API.
3Cited by36 opinions
- Saviano v. CommissionerUnited States Tax Court · 1983
- Stolk v. CommissionerUnited States Tax Court · 1963
- Smith's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- M. O. Rife and Maidee W. Rife v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Douglas v. CommissionerUnited States Tax Court · 1959
31 more not listed; retrieve them via the Exa API.