Zimmerman Steel Co. v. Commissioner of Int. Rev.

WOODROUGH, Circuit Judge.

The petitioning taxpayer (which is now in bankruptcy) seeks review of a decision of the Board of Tax Appeals sustaining the Commissioner’s deficiency assessments for the tax years 1936 and 1937, based upon the refusal of the Commissioner to allow the taxpayer deductions which it claimed on account of interest accrued upon its debt for those years as shown on its books kept on the accrual basis. The findings of fact made by the Board appear with the Board’s opinion, reported 45 B.T.A. 1041.

The Board based its decision that the interest upon the taxpayer’s debt accruing…