Koppers Co. v. Commissioner
United States Tax Court
Petitioner and 5 other affiliates were severally liable for a deficiency in tax under a consolidated income tax return filed in 1930 by 66 affiliates. In the taxable year 1940 petitioner paid the major portion of the deficiency and interest. Petitioner filed a separate return for 1940 and claimed the full amount of the interest payment as a deduction. Petitioner kept its books on the accrual basis.
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Petitioner and 5 other affiliates were severally liable for a deficiency in tax under a consolidated income tax return filed in 1930 by 66 affiliates. In the taxable year 1940 petitioner paid the major portion of the deficiency and interest. Petitioner filed a separate return for 1940 and claimed the full amount of the interest payment as a deduction. Petitioner kept its books on the accrual basis. The other affiliates were not shown to be insolvent or otherwise unable to pay their proportionate share of the deficiency. Held, to the extent petitioner paid interest on more than its…
1Opinion of the Court
Koppers Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Koppers Co. v. Commissioner
Docket No. 6232
United States Tax Court
8 T.C. 886; 1947 U.S. Tax Ct. LEXIS 219;
April 25, 1947, Promulgated
Decision will be entered under Rule 50.
Petitioner and 5 other affiliates were severally liable for a deficiency in tax under a consolidated income tax return filed in 1930 by 66 affiliates. In the taxable year 1940 petitioner paid the major portion of the deficiency and interest. Petitioner filed a separate return for 1940 and claimed the full amount of the interest payment as a…
2Cases cited3 opinions
- Phillips-Jones Corp. v. ParmleySupreme Court of the United States · 1937
- Jolson v. CommissionerUnited States Tax Court · 1944
- Koppers Co. v. CommissionerUnited States Tax Court · 1947