Finen v. Commissioner
United States Tax Court
Petitioners submitted an offer in compromise of their unpaid 1943 and 1944 deficiencies in tax, penalties, and interest. The terms of the offer were contained in two documents. In one, on standard Treasury Form 656-C, petitioners offered to pay $ 60,000 in compromise of their unpaid liability.
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Petitioners submitted an offer in compromise of their unpaid 1943 and 1944 deficiencies in tax, penalties, and interest. The terms of the offer were contained in two documents. In one, on standard Treasury Form 656-C, petitioners offered to pay $ 60,000 in compromise of their unpaid liability. In the other, a so-called collateral agreement, they agreed, as additional consideration for the acceptance of the offer, to pay out of their annual income during the 11-year period ending December 31, 1966, certain percentages of amounts realized in excess of a specified amount until their payments,…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined deficiencies in income tax in the amounts of $2,748.22, $762.11, $990.40, and $4,882.33 for the years 1956, 1958, 1959, and 1960, respectively. The sole question for decision is whether petitioners are entitled to interest deductions with respect to the amounts paid by them during the taxable years pursuant to the terms of a compromise agreement relating to their 1943 and 1944 unpaid deficiencies in tax, penalities, and interest. All of the facts have been stipulated.
Petitioners, husband and wife, filed joint income tax returns for 1956, 1958,…
2Cases cited3 opinions
- Helvering v. American Dental Co.Supreme Court of the United States · 1943
- United States v. LaneCourt of Appeals for the Fifth Circuit · 1962
- Lustig v. United StatesUnited States Court of Claims · 1956
3Cited by10 opinions
- Amos v. Comm'rUnited States Tax Court · 1966
- Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
- Alan I. Begner, Cory Begner v. United StatesCourt of Appeals for the Eleventh Circuit · 2005
- Waller v. United StatesDistrict Court, E.D. California · 1991
- Dowell v. CommissionerUnited States Tax Court · 1980
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