Estate of Stamos v. Commissioner
United States Tax Court
On their joint Federal income tax return for 1963, the taxpayers elected to capitalize certain tax and interest payments pursuant to sec. 266, I.R.C. 1954, and the regulations promulgated thereunder.
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On their joint Federal income tax return for 1963, the taxpayers elected to capitalize certain tax and interest payments pursuant to sec. 266, I.R.C. 1954, and the regulations promulgated thereunder. After the Commissioner subsequently determined that the taxpayers were not entitled to certain unrelated deductions which they had claimed on their 1963 return and consequently increased their taxable income from a loss of $ 1.26 to taxable income of $ 4,855.48, the taxpayers attempted to revoke their election and instead deduct the tax and interest payments in 1963. Held, the taxpayers' initial…
1Opinion of the Court
Estate of George Stamos, Deceased, Evelyn J. Stamos, Executrix, and Evelyn J. Stamos, Petitioners v. Commissioner of Internal Revenue, Respondent
Estate of Stamos v. Commissioner
Docket No. 3349-67
United States Tax Court
55 T.C. 468; 1970 U.S. Tax Ct. LEXIS 10;
December 14, 1970, Filed
Decision will be entered for the respondent.
On their joint Federal income tax return for 1963, the taxpayers elected to capitalize certain tax and interest payments pursuant to sec. 266, I.R.C. 1954, and the regulations promulgated thereunder. After the Commissioner subsequently determined that the taxpayers were…
Also in this document: Dissent.
2Cases cited40 opinions
- J. E. Riley Investment Co. v. CommissionerSupreme Court of the United States · 1940
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
- Pollack v. CommissionerUnited States Tax Court · 1966
- Hertz Corp. v. United StatesSupreme Court of the United States · 1960
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