Legal Opinion
Andrew A. Sandor and Jeanne Sandor v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 28, 1976No. 74-3030PublishedCited by 87 opinions
1Opinion of the Court
OPINION
Before CARTER and WRIGHT, Circuit Judges, and EAST, 1 District Judge. PER CURIAM:
Petitioner, a cash basis taxpayer, appeals a Tax Court decision [62 T.C. 469 (1974)] which upheld the Commissioner’s disallowance of a prepaid interest deduction. We affirm.
In November 1968, petitioner arranged with a bank for a five year loan of $100,000 at 7V2% annual interest. On December 27, he prepaid $38,041.61, the interest to accrue over the next five years. The promissory note for the loan itself was not signed until December 31. Petitioner’s 1968 taxable income was $210,001, a substantial…
2Cases cited10 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Hormel v. HelveringSupreme Court of the United States · 1941
- Commissioner v. HansenSupreme Court of the United States · 1959
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
5 more not listed; retrieve them via the Exa API.
3Cited by87 opinions
- Siegel v. CommissionerUnited States Tax Court · 1982
- Baird v. CommissionerUnited States Tax Court · 1977
- Bernard Resnik and Beverly Resnik v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1977
- Prabel v. CommissionerUnited States Tax Court · 1988
- Van Raden v. CommissionerUnited States Tax Court · 1979
82 more not listed; retrieve them via the Exa API.