Aizawa v. Commissioner
United States Tax Court
Petitioners owned rental property which was subject to a recourse mortgage. Upon default, the property was acquired by the mortgagee at a foreclosure sale, and a deficiency judgment obtained against petitioners. Held, in determining petitioners' loss, the amount of the proceeds of the foreclosure sale constitutes the "amount realized" under sec. 1001(a), I.R.C.
1Opinion of the Court
Joseph Y. and Noriyo Aizawa, Petitioners v. Commissioner of Internal Revenue, Respondent
Aizawa v. Commissioner
Docket No. 12827-90
United States Tax Court
99 T.C. 197; 1992 U.S. Tax Ct. LEXIS 62; 99 T.C. No. 10;
August 6, 1992, Filed
Decision will be entered under Rule 155.
Petitioners owned rental property which was subject to a recourse mortgage. Upon default, the property was acquired by the mortgagee at a foreclosure sale, and a deficiency judgment obtained against petitioners. Held, in determining petitioners' loss, the amount of the proceeds of the foreclosure sale constitutes the "amount…
2Cases cited16 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Helvering v. HammelSupreme Court of the United States · 1941
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Commissioner v. TuftsSupreme Court of the United States · 1983
- Waddell v. CommissionerUnited States Tax Court · 1986
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