La Croix v. Commissioner
United States Tax Court
1. The petitioners' limited partnership purchased an office building and made a "prepayment of interest" in the amount of $ 250,000 which the partnership claimed as an interest deduction in the year of payment.
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1. The petitioners' limited partnership purchased an office building and made a "prepayment of interest" in the amount of $ 250,000 which the partnership claimed as an interest deduction in the year of payment. The sales contract called for additional periodic interest and principal payments and required at some point the crediting against principal due of "interest paid in advance" or "prepaid interest" in the amount of $ 250,000. Held: The petitioners' partnership is not entitled to an interest deduction under sec. 163(a) for this $ 250,000 payment. This payment was in effect a deposit or…
1Opinion of the Court
SteRRett, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax as follows:
Petitioners Docket No. Deficiency
Kenneth. D. LaCroix and Rhetta S. LaCroix_ 5128-71 $3, 002. 00
Kenneth L. Lorenz and Florence H. Lorenz- 6129-71 2, 415. 00
Orville W. Bottorff and Martha L. Bottorff_ 5130-71 2, 541. 00
Robert L. Duey and Nancy T. Duey_ 5133-71 8, 263. 00
Robert E. Washbon and Margaret C. Washbon_ 5134-71 1, 830. 11
John H. Ryan and Lois L. Ryan_ 5135-71 2, 461. 00
Charles Ii. Ransom and Billie N. Ransom- 5138-71 2, 155. 00
Charles W. Plows and Nancy H. Plows_ 5139-71 3, 689. 00
Pete…
2Cases cited27 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Maryland Casualty Co. v. United StatesSupreme Court of the United States · 1920
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3Cited by28 opinions
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- Derr v. CommissionerUnited States Tax Court · 1981
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