Legal Opinion

Armour v. Commissioner

United States Tax Court

Decided March 7, 1946No. Docket No. 4471Published

1. Petitioner was liable as transferee for personal holding company surtax deficiencies and interest thereon of a liquidated and dissolved corporation. In 1940 petitioner paid the deficiencies and interest, all of which had accrued after the date of transfer. Held, the interest is deductible by petitioner under section 23 (b), Internal Revenue Code. Koppers Co., 3 T. C. 62; affd., 151 Fed.

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1. Petitioner was liable as transferee for personal holding company surtax deficiencies and interest thereon of a liquidated and dissolved corporation. In 1940 petitioner paid the deficiencies and interest, all of which had accrued after the date of transfer. Held, the interest is deductible by petitioner under section 23 (b), Internal Revenue Code. Koppers Co., 3 T. C. 62; affd., 151 Fed. (2d) 267, and Robert L. Smith, 6 T. C. 255, followed. 2. Petitioner paid $ 200 in miscellaneous legal fees in connection with the management, conservation, or maintenance of property held for the production…

1Opinion of the Court

Philip D. Armour, Petitioner, v. Commissioner of Internal Revenue, Respondent

Armour v. Commissioner

Docket No. 4471

United States Tax Court

6 T.C. 359; 1946 U.S. Tax Ct. LEXIS 276;

March 7, 1946, Promulgated

Decision will be entered under Rule 50.

1. Petitioner was liable as transferee for personal holding company surtax deficiencies and interest thereon of a liquidated and dissolved corporation. In 1940 petitioner paid the deficiencies and interest, all of which had accrued after the date of transfer. Held, the interest is deductible by petitioner under section 23 (b), Internal Revenue Code.…

2Cases cited8 opinions

  1. Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
  2. Greene Motor Co. v. CommissionerUnited States Tax Court · 1945
  3. Koppers Co. v. CommissionerUnited States Tax Court · 1944
  4. Cammack v. CommissionerUnited States Tax Court · 1945
  5. Bingham v. CommissionerUnited States Tax Court · 1943

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