Kramer v. Commissioner
United States Board of Tax Appeals
1. In 1926 one of the petitioners owned an undivided two-thirds interest, and another an undivided one-third interest, in certain real estate which was sold in said year for a total lump sum or undivided consideration of $450,000, consisting of $200,000 cash and a mortgage note for $250,000. Prior to the sale, the petitioners agreed that one should take $50,000 of the cash and the mortgage note for $250,000, and that the other should take $150,000 of the cash.
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1. In 1926 one of the petitioners owned an undivided two-thirds interest, and another an undivided one-third interest, in certain real estate which was sold in said year for a total lump sum or undivided consideration of $450,000, consisting of $200,000 cash and a mortgage note for $250,000. Prior to the sale, the petitioners agreed that one should take $50,000 of the cash and the mortgage note for $250,000, and that the other should take $150,000 of the cash. Held, that the owner of the two-thirds interest received an initial payment in excess of one-fourth of the purchase price, and that…
1Opinion of the Court
OPINION.
Teammell :
These are consolidated proceedings for the redetermi-nation of deficiencies in income tax as follows:
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The petitioner, Olga R,. Kramer, agreed at the hearing that the deficiency determined against her by the respondent in Docket No. 62843 is correct, and that judgment may be entered accordingly.
At the hearing, counsel for the petitioners suggested the death of the petitioner, Julius Kramer, and moved that Walter E. Kramer, executor of the estate of said decedent, be substituted as petitioner, which motion was granted.
*1044The issues submitted for decision are: (1)…
2Cases cited5 opinions
- Rensselaer & S. R. v. IrwinCourt of Appeals for the Second Circuit · 1918
- Jones v. . CohenSupreme Court of North Carolina · 1880
- Hunter v. StateSupreme Court of Arkansas · 1895
- Stookey v. CarterIllinois Supreme Court · 1879
- Freedman v. Davoplane Bed Co.Court of Appeals for the Seventh Circuit · 1916
3Cited by12 opinions
- W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Farha v. CommissionerUnited States Tax Court · 1972
- G. E. Employees Securities Corp. v. ManningDistrict Court, D. New Jersey · 1941
- Timanus v. CommissionerUnited States Tax Court · 1959
- Boulevard Frocks, Inc. v. CommissionerUnited States Tax Court · 1943
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