Sec. 267(a)(3) regs. invalid; Tax Court allows interest deduction in year accrued.: An article from: The Tax Adviser

by Richard Godshalk, Alan Shapiro, Michael Cooper

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This digital document is an article from The Tax Adviser, published by American Institute of CPA's on March 1, 1995. The length of the article is 834 words. The page length shown above is based on a typical 300-word page. The article is delivered in HTML format and is available in your Amazon.com Digital Locker immediately after purchase. You can view it with any web browser.

From the supplier: The Tax Court ruled in Tate & Lyle, Inc. that interest deductions of accrued, unpaid interest on a loan with an affiliate should not be subject to deferral until actually paid under IRC section 267(a)(3). The IRS asserted that the matching principle of section 267(a)(3) is to be applied even though the taxpayer may be exempt from US taxation under a tax treaty. The court found that the matching principle is only to be implicated when inconsistencies in accounting method exist. The court found the IRS regulations beyond the scope of IRS authority.

Citation Details
Title: Sec. 267(a)(3) regs. invalid; Tax Court allows interest deduction in year accrued.
Author: Richard Godshalk
Publication: The Tax Adviser (Magazine/Journal)
Date: March 1, 1995
Publisher: American Institute of CPA's
Volume: 26 Issue: n3 Page: 154(3)

Distributed by Thomson Gale

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