Commissioner of Internal Revenue v. Philadelphia Title Ins. Co

U.S. Court of Appeals for the Third Circuit October 22, 1952

Commissioner of Internal Revenue v. Philadelphia Title Ins. Co, 199 F.2d 301 (3d Cir. 1952)

42 A.F.T.R. (P-H) 696; 1952 U.S. App. LEXIS 4108

Goodrich, McLAUGHLIN, Per Curiam, Staley

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.

Reference

Full Case Name: Commissioner of Internal Revenue v. Philadelphia Title Ins. Co.
Status: Published