Schubel v. Commissioner
United States Tax Court
Held, points and other "prepaid finance charges" withheld by the lender may not be deducted by petitioners in the year of borrowing under sec. 461(g)(2), I.R.C. 1954, since they were not "paid" within the taxable year.
1Opinion of the Court
Roger A. Schubel and Shirley D. Schubel, Petitioners v. Commissioner of Internal Revenue, Respondent
Schubel v. Commissioner
Docket No. 2314-80
United States Tax Court
77 T.C. 701; 1981 U.S. Tax Ct. LEXIS 53;
September 28, 1981, Filed
Decision will be entered for the respondent.
Held, points and other "prepaid finance charges" withheld by the lender may not be deducted by petitioners in the year of borrowing under sec. 461(g)(2), I.R.C. 1954, since they were not "paid" within the taxable year.
John E. Cicero II, for the petitioners.
J. Michael Melvin, for the respondent.
Ekman, Judge.
EKMAN
OPINION
Respond…
2Cases cited28 opinions
- Helvering v. PriceSupreme Court of the United States · 1940
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Sandor v. CommissionerUnited States Tax Court · 1974
- Andrew A. Sandor and Jeanne Sandor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- G. Douglas Burck and Marjorie W. Burck v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
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