...they are paid or accrued. Section 1.1 64-1 (a) of the regulations provides, in part, that, in general, taxes are deductible only by the person on whom they are imposed. Accordingly, in the instant case the amounts paid by the taxpayer as real property taxes are deductible...

...allows a deduction to the corporation rather than the shareholder whose tax is paid (sec. 164(e)). This rule is inconsistent with the general rule that...National Bank v. Commissioner 457 US 1103 (1983). Sec. 164(e) could be repealed. Possible Proposal The Committee may wish to consider the repeal of section...