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

Court of Appeals for the Third Circuit·Decided October 22, 1952·No. 10801·Published

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.

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).

Pincite

199 F.2d 301 (Commissioner of Internal Revenue v. Philadelphia Title Ins. Co) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Opinion

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