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

Annotate this Case
US Court of Appeals for the Third Circuit - 199 F.2d 301 (3d Cir. 1952) 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.


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.