Legal Opinion

Roemer v. Commissioner

United States Tax Court

Decided December 12, 1977No. Docket Nos. 3837-74, 3838-74, 3915-74Published

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

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
  3. Mayerson v. CommissionerUnited States Tax Court · 1966
  4. Goldstein v. CommissionerUnited States Tax Court · 1965
  5. Sandor v. CommissionerUnited States Tax Court · 1974

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