Commissioner of Internal Revenue v. Philadelphia Title Ins. Co

Third Circuit

Commissioner of Internal Revenue v. Philadelphia Title Ins. Co

199 F.2d 301, 42 A.F.T.R. (P-H) 696, 1952 U.S. App. LEXIS 4108

CourtCourt of Appeals for the Third Circuit

DecidedOctober 22, 1952

Docket10801

StatusPublished

This text of 199 F.2d 301 (Commissioner of Internal Revenue v. Philadelphia Title Ins. Co) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Commissioner of Internal Revenue v. Philadelphia Title Ins. Co, 199 F.2d 301, 42 A.F.T.R. (P-H) 696, 1952 U.S. App. LEXIS 4108 (3d Cir. 1952).

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Opinion

PER CURIAM.

This appeal by the Commissioner relates to the accruability of Pennsylvania share taxes paid by the taxpayer. The tax court permitted the taxpayer to accrue the taxes for the year in which it was required to file its Pennsylvania return although payment was not made until the next year. The taxpayer is on an accrual basis.

We think the conclusion reached by the tax court, 17 T.C. 1068, is correct.

The decision of the tax court will be affirmed.

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PER CURIAM.

This appeal by the Commissioner relates to the accruability of Pennsylvania share taxes paid by the taxpayer. The tax court permitted the taxpayer to accrue the taxes for the year in which it was required to file its Pennsylvania return although payment was not made until the next year. The taxpayer is on an accrual basis.

We think the conclusion reached by the tax court, 17 T.C. 1068, is correct.

The decision of the tax court will be affirmed.

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Bluebook (online)

199 F.2d 301, 42 A.F.T.R. (P-H) 696, 1952 U.S. App. LEXIS 4108, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commissioner-of-internal-revenue-v-philadelphia-title-ins-co-ca3-1952.

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