Read the following excerpt from a US court opinion:
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to § 164(a), they must first qualify as real property taxes, which are defined in Treas. Reg. § 1.164r-3(b) (as amended in 1964) as “taxes imposed on interests in real property and levied for the general public welfare. ...” Treas. Reg. § 1.164—3(b); Black v. Comm’r, 60 T.C. 108, 113 (U.S.Tax Ct.1973). Thus under Treas. Reg. § 1.164-3(b), deductions pursuant to § 164(a)(1) may only be taken on taxes actually imposed on interests in real property. Furthermore, Treas. Reg. § 1.164-1 (as amended in 1978), which states that generally, “taxes are deductible only by the person upon whom they are imposed,” reinforces the notion that real property taxes must first be imposed before they may be deducted for federal income tax purposes. See Hynes v. Comm’r, 74 T.C. 1266, 1289 (U.S.Tax Ct.1980) . In order to determine upon whom local
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What is the most suitable continuation to the opinion? Your options are:
A. holding that 18 percent interest on delinquent real property taxes under florida law is not in nature of penalty
B. holding unemployment taxes accrued when employees were terminated not when the amount of compensation taxes are determinable
C. holding petitioner could not deduct real estate taxes imposed on property he did not own because these taxes were not imposed on him
D. holding that taxes were a claim against the estate that had to be filed in probate court thus reversing an order requiring heirs to pay taxes on estate property because the district court did not have jurisdiction
E. holding that permit fees imposed by statute were not taxes
Reply with [A, B, C, D, E] only.