Simon J. Murphy Co. v. Commissioner
United States Tax Court
Allocation of Deductions -- Distortion of Income -- Clear Reflection -- Sec. 45, I. R. C., 1939. -- The Commissioner, in order to reflect income clearly, may allocate or apportion a deduction for real estate taxes for 12 months, accrued by the owner corporation, for a tax period of 11 days preceding transfer of the rental real estate in complete liquidation to another corporation, which owned all of its stock.
1Opinion of the Court
OPINION.
Murdock, Judge,:
The Commissioner determined a deficiency in income tax of $15,182.39 for 1949 and one of $6,378.14 for the first 11 days in January 1950 against Simon J. Murphy Company, herein called Murphy. He also determined that Social Research Foundation, Inc., herein called Research, is liable as a transferee for those taxes. Research concedes that it is liable for any taxes due from Murphy. The parties have stipulated the facts and, as thus agreed to, they are adopted as the findings of fact.
The returns of Murphy for the taxable years were filed with the collector of internal…
2Cases cited11 opinions
- Magruder v. SuppleeSupreme Court of the United States · 1942
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Jud Plumbing & Heating, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
- Standard Paving Co. v. Commissioner of Internal Revenue. Standard Paving Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
- Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
6 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Huber Homes, Inc. v. CommissionerUnited States Tax Court · 1971
- Kerry Inv. Co. v. CommissionerUnited States Tax Court · 1972
- Local Finance Corp. v. CommissionerUnited States Tax Court · 1967
- Marc's Big Boy-Prospect, Inc. v. CommissionerUnited States Tax Court · 1969
10 more not listed; retrieve them via the Exa API.