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

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    The United States Court of Appeals for the Third Circuit affirmed the decision of the Tax Court allowing a title insurance company filing taxes on an accrual basis to accrue Pennsylvania share taxes for the year in which it was required to file its state return, even though payment was not made until the following year. The Commissioner of Internal Revenue appealed the Tax Court's decision permitting the taxpayer to accrue the taxes in this manner. The appellate court agreed with the Tax Court's conclusion.

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    Filed: 1952-10-22 Precedential Status: Precedential Citations: 199 F.2d 301 Docket: 10801

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    The United States Court of Appeals for the Third Circuit affirmed the decision of the Tax Court allowing a title insurance company filing taxes on an accrual basis to accrue Pennsylvania share taxes for the year in which it was required to file its state return, even though payment was not made until the following year. The Commissioner of Internal Revenue appealed the Tax Court's decision permitting the taxpayer to accrue the taxes in this manner. The appellate court agreed with the Tax Court's conclusion.

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

    Uploaded by

    Scribd Government Docs
    The United States Court of Appeals for the Third Circuit affirmed the decision of the Tax Court allowing a title insurance company filing taxes on an accrual basis to accrue Pennsylvania share taxes for the year in which it was required to file its state return, even though payment was not made until the following year. The Commissioner of Internal Revenue appealed the Tax Court's decision permitting the taxpayer to accrue the taxes in this manner. The appellate court agreed with the Tax Court's conclusion.

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    199 F.

    2d 301

    COMMISSIONER OF INTERNAL REVENUE


    v.
    PHILADELPHIA TITLE INS. CO.
    No. 10801.

    United States Court of Appeals Third Circuit.


    Argued October 16, 1952.
    Decided October 22, 1952.

    Harry Marselli, Washington, D. C. (Ellis N. Slack, Acting Asst. Atty.


    Gen., on the brief), for appellant.
    Herman H. Greenberg, Philadelphia, Pa., for appellee.
    Before GOODRICH, McLAUGHLIN and STALEY, Circuit Judges.
    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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