Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 55-65

1955-1 C.B. 277

Sec. 164

Caution: Modified by Rev. Rul. 60-127

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Rev. Rul. 55-65

The two percent addition imposed by section 71.10(9)(c) of the Wisconsin Statutes (1953) on corporations, organized in the State of Wisconsin and licensed to do business therein, for failure to pay income tax in full on or before the 15th day of the third month following the close of the income year is a part of the tax and consequently is deductible under section 23(c) of the Internal Revenue Code of 1939.

The additions imposed by section 71.13(1) of the Wisconsin law to be added to the initial amount of income tax for delinquency in payment of the tax when due and under section 71.11(40) for failure to file an income tax return within the time prescribed by law are penalties and therefore are not deductible. See Kossar & Co., Inc. v. Commissioner , 16 B.T.A. 952