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

Commissioner of Internal Revenue v. Philadelphia Title Ins. Co

Commissioner of Internal Revenue v. Philadelphia Title Ins. Co
U.S. Court of Appeals for the Third Circuit · Decided October 22, 1952 · Goodrich, McLAUGHLIN, Per Curiam, Staley
199 F.2d 301; 42 A.F.T.R. (P-H) 696; 1952 U.S. App. LEXIS 4108 (Federal Reporter, Second Series)

Commissioner of Internal Revenue v. Philadelphia Title Ins. Co

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.

Case-law data current through December 31, 2025. Source: CourtListener bulk data.

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