Reinhardt v. Commissioner
United States Tax Court
Petitioners deducted as real estate taxes a payment made in 1973 to redeem their property from the State of California. The redemption was necessitated by the existence of a tax lien on the property attributable to unpaid real estate taxes which accrued on such property prior to the time petitioners purchased the property.
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Petitioners deducted as real estate taxes a payment made in 1973 to redeem their property from the State of California. The redemption was necessitated by the existence of a tax lien on the property attributable to unpaid real estate taxes which accrued on such property prior to the time petitioners purchased the property. The payment covered not only the delinquent taxes but also various penalties, costs, and fees that must be paid when redeeming property from the State of California. Held, the delinquent taxes, delinquent penalty, costs, and fees must be capitalized, but petitioners may…
1Opinion of the Court
Goffe, Judge:
The Commissioner determined a deficiency of $2,963.90 in the Federal income tax of petitioners for the taxable year 1973. After concessions,1 the only issue for our decision is whether petitioners may deduct any portion of a $8,462.27 payment made in 1973 either as taxes or as interest.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
Petitioners Al S. Reinhardt and Miriam Reinhardt, husband and wife, timely filed a joint Federal income tax return for their taxable year 1973. At…
2Cases cited10 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Enoch v. CommissionerUnited States Tax Court · 1972
- Magruder v. SuppleeSupreme Court of the United States · 1942
- United States v. ChildsSupreme Court of the United States · 1924
- Meilink v. Unemployment Reserves Comm'n of Cal.Supreme Court of the United States · 1942
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3Cited by2 opinions
- In re FowlerUnited States Bankruptcy Court, E.D. California · 2012
- Reinhardt v. CommissionerUnited States Tax Court · 1980