Keith v. Commissioner
United States Tax Court
1. Held: Amounts remitted by petitioner to district director with offer in compromise of assessed prior years' liability for tax, additions to tax, and interest, in which petitioner agreed that if offer rejected, the amounts deposited could be applied on the liability, and which remittances the district director deposited in special deposit account until claims rejected, do not constitute payments on the liability at the times remitted so as to entitle petitioner to a…
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1. Held: Amounts remitted by petitioner to district director with offer in compromise of assessed prior years' liability for tax, additions to tax, and interest, in which petitioner agreed that if offer rejected, the amounts deposited could be applied on the liability, and which remittances the district director deposited in special deposit account until claims rejected, do not constitute payments on the liability at the times remitted so as to entitle petitioner to a deduction for interest at that time. Under the circumstances remittances do not become payments until applied to the liability…
1Opinion of the Court
OPINION.
Drennen, Judge:
Respondent determined deficiencies in petitioners’ income tax in the amounts of $2,255.85 and $271.05 for the years 1954 and 1956, respectively.1
The issues presented are: (1) Whether the petitioners are entitled to an interest deduction for any part of certain payments on account of deficiencies in income tax, additions to tax, and interest for the years 1942 to 1947, inclusive, made to the district director of internal revenue in each of the years 1954 and 1956; and (2) if so, what amounts of such payments are deductible.
All the facts were stipulated and are so found.
Pe…
2Cases cited15 opinions
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- Rosenman v. United StatesSupreme Court of the United States · 1945
- Lewyt Corp. v. CommissionerSupreme Court of the United States · 1955
- Plunkett v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1941
- Lewyt Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
10 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Amos v. Comm'rUnited States Tax Court · 1966
- Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
- Brink v. CommissionerUnited States Tax Court · 1962
- Perkins v. CommissionerUnited States Tax Court · 1989
- Fortugno v. CommissionerUnited States Tax Court · 1963
13 more not listed; retrieve them via the Exa API.