Sandor v. Commissioner of Internal Revenue - United States Court of Appeals for the Ninth Circuit

Sandor v. Commissioner of Internal Revenue

By United States Court of Appeals for the Ninth Circuit

  • Release Date - Published: 1976-05-28
  • Book Genre: Law
  • Author: United States Court of Appeals for the Ninth Circuit
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Sandor v. Commissioner of Internal Revenue United States Court of Appeals for the Ninth Circuit read online review & book description:

Petitioner, a cash basis taxpayer, appeals a Tax Court decision [62 T.C. 469 (1974)] which upheld the Commissioner's disallowance of a prepaid interest deduction. We affirm. In November 1968, petitioner arranged with a bank for a five year loan of $100,000 at 7 1/2% annual interest. On December 27, he prepaid $38,041.61, the interest to accrue over the next five years. The promissory note for the loan itself was not signed until December 31. Petitioner's 1968 taxable income was $210,001, a substantial increase over his income for each of the previous four years.

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