(Download) "Carlisle Tire & Rubber Co. v. Commissioner of Internal Revenue." by Circuit Court of Appeals, Third Circuit * Book PDF Kindle ePub Free
eBook details
- Title: Carlisle Tire & Rubber Co. v. Commissioner of Internal Revenue.
- Author : Circuit Court of Appeals, Third Circuit
- Release Date : January 28, 1948
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 69 KB
Description
The Commissioner has asserted and the Tax Court has found a deficiency in petitioners excess profits tax return for the year 1943. The instant appeal raises three questions: (1) Whether petitioner, having entered into a written compromise agreement with the Commissioner concerning indebtedness on excise taxes due the government, was, pursuant to the terms of such agreement, entitled to deduct, as an expense, interest accrued but not paid on the original amount of said excise taxes; (2) whether the Tax Court erred in excluding evidence which petitioner offered, to the effect that certain employees in the Philadelphia office of the Collector of Internal Revenue construed the compromise agreement to require such payment of interest; and (3) whether petitioner could treat as invested capital the difference between the amount which petitioner owed a non-stockholder creditor and that which petitioner actually paid in settlement of the creditors claim. All three questions were resolved against petitioner by the Tax Court.