Roemer v. Commissioner
United States Tax Court
In five separate transactions petitioners paid certain amounts which were designated as prepaid interest. Held, Rev. Rul. 68-643, 1968-2 C.B. 76, by its terms, applies retroactively to an interest prepayment sufficient to pay 3 2/3 years' interest where such amount may be, and is applied, at the sole discretion of the lender, to satisfy interest obligations arising during a period in excess of 5 years from the prepayment date.
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In five separate transactions petitioners paid certain amounts which were designated as prepaid interest. Held, Rev. Rul. 68-643, 1968-2 C.B. 76, by its terms, applies retroactively to an interest prepayment sufficient to pay 3 2/3 years' interest where such amount may be, and is applied, at the sole discretion of the lender, to satisfy interest obligations arising during a period in excess of 5 years from the prepayment date. Held, further, Rev. Rul. 68-643 applies retroactively to the entire amount of an interest prepayment for an indefinite period where there is at least a probability that…
1Opinion of the Court
Paul F. Roemer, Jr., and Marcia E. Roemer, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Roemer v. Commissioner
Docket Nos. 3837-74, 3838-74, 3915-74
United States Tax Court
69 T.C. 440; 1977 U.S. Tax Ct. LEXIS 9;
December 12, 1977, Filed
Decisions will be entered under Rule 155.
In five separate transactions petitioners paid certain amounts which were designated as prepaid interest. Held, Rev. Rul. 68-643, 1968-2 C.B. 76, by its terms, applies retroactively to an interest prepayment sufficient to pay 3 2/3 years' interest where such amount may be, and is applied, at the sole…
2Cases cited17 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Mayerson v. CommissionerUnited States Tax Court · 1966
- Goldstein v. CommissionerUnited States Tax Court · 1965
- Sandor v. CommissionerUnited States Tax Court · 1974
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