Central & Pacific Improv. Corp. v. Commissioner
United States Board of Tax Appeals
1. The whole amount of award to petitioner for property condemned and taken by the city for public use should be considered as received by him in the taxable year, where a part of it is offset against assessments for improvements. 2. Benefit assessments paid by such award may be added to the cost of the property for the purpose of determining taxable gain from the award received for the taking of a portion thereof.
1Opinion of the Court
OPINION.
Arnold:
This appeal is for the redetermination of a deficiency asserted by the respondent in income tax for the year 1930 in the amount of $16,109.42. It is alleged that the respondent erred in determining a profit from the involuntary conversion of certain property belonging to the petitioner. The facts are stipulated.
The petitioner is a corporation organized under the laws of the State of California and has its principal place of business at 123 West Washington Boulevard, Los Angeles, California.
During the month of November 1913 petitioner, at a cost of $282,-497.12, acquired fee…
2Cases cited5 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Norwood v. BakerSupreme Court of the United States · 1898
- United States v. Boston & Maine RailroadSupreme Court of the United States · 1929
- Spring Street Co. v. City of Los AngelesCalifornia Supreme Court · 1915
- San Francisco-Oakland Terminal Railways v. County of AlamedaCalifornia Court of Appeal · 1924
3Cited by1 opinion
- Central & Pacific Improv. Corp. v. CommissionerUnited States Board of Tax Appeals · 1935