Standing v. Commissioner
United States Tax Court
Held, taxpayer James J. Standing was on an accrual method for reporting business income and held, further, items representing interest on income tax deficiencies for prior years and expenses incurred in settling the deficiencies were properly accrued under section 22 (n) (1), I. R. C. 1939, as deductions allowed by section 23 attributable to the business carried on by James J. Standing.
1Opinion of the Court
MulRONey, Judge:
The respondent determined a deficiency in the income tax of J ames J. Standing and Marie S. Standing for the taxable year 1951 in the amount of $23,542.96. Some of the adjustments made by respondent were not put in issue by petitioners and others have been conceded. The only issue presented here is whether petitioners were entitled to deduct as expenses in arriving at adjusted gross income (under sec. 22 (n (1), I. R. C. 1939) for the year 1951 the sum of $29,043.32 representing interest on income tax deficiencies and other expenses incurred in settling the deficiencies, which…
2Cases cited5 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Kornhauser v. United StatesSupreme Court of the United States · 1928
- Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
- Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
- WD Haden Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
3Cited by34 opinions
- Polk v. CommissionerUnited States Tax Court · 1958
- Nick Kikalos and Helen Kikalos v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1999
- Commissioner of Internal Revenue v. James J. Standing and Marie S. StandingCourt of Appeals for the Fourth Circuit · 1958
- James L. Redlark Cheryl L. Redlark v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1998
- Redlark v. Comm'rUnited States Tax Court · 1996
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