De Soto Sec. Co. v. Commissioner
United States Tax Court
In computing the deduction for taxes "paid or accrued" (sec. 505 (a) (1), I. R. C. 1939) in determining subchapter A net income for purpose of the holding company surtax on undistributed net income, a cash basis taxpayer which deducted taxes "accrued" during the tax year may not also deduct taxes paid during that year with respect to income of previous years.
1Opinion of the Court
OPINION.
Raum, Judge:
Respondent has determined a deficiency in the personal holding company surtax, of petitioner for its fiscal year ended June 30, 1950, in the amount of $16,904.29. In computing its sub-chapter A pet income petitioner claimed and has been allowed a deduction for income taxes accrued in respect of its fiscal year ended June 30, 1950. The sole issue is whether in making such computation petitioner may also deduct amounts paid during the above taxable year in respect of income taxes owed on account of prior taxable years.
All of the facts have been stipulated and are so found.
Pet…
2Cases cited5 opinions
- Commissioner of Internal Revenue v. Clarion Oil Co.Court of Appeals for the D.C. Circuit · 1945
- Aramo-Stiftung v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Clarion Oil Co. v. CommissionerUnited States Tax Court · 1943
- Birmingham v. Loetscher Co.Court of Appeals for the Eighth Circuit · 1951
- Joan Carol Corp. v. CommissionerUnited States Tax Court · 1949
3Cited by16 opinions
- Lawrence v. CommissionerUnited States Tax Court · 1957
- De Soto Securities Company v. Commission of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
- Arc Realty Co. v. CommissionerUnited States Tax Court · 1960
- Patten Fine Papers, Inc. v. CommissionerUnited States Tax Court · 1957
- Mills, Inc. v. CommissionerUnited States Tax Court · 1957
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