Legal Opinion

Schubel v. Commissioner

United States Tax Court

Decided September 28, 1981No. Docket No. 2314-80Published

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

  1. Helvering v. PriceSupreme Court of the United States · 1940
  2. Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
  3. Sandor v. CommissionerUnited States Tax Court · 1974
  4. Andrew A. Sandor and Jeanne Sandor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
  5. G. Douglas Burck and Marjorie W. Burck v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976

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