Legal Opinion

Title & Trust Co. v. Commissioner

United States Board of Tax Appeals

Decided September 10, 1935No. Docket No. 73785Published

Prior to 1931 petitioner purchased from the vendor of houses the contracts for the sale of a number of the houses and lots. In 1931 the purchasers defaulted and petitioner canceled the contracts and took over the houses and lots. The fair market value of the realty so acquired by petitioner was less than the amount of petitioner's unrecovered cost of the sale contracts, and it is held that that difference represented a deductible loss to the petitioner.

1Opinion of the Court

TITLE & TRUST COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Title & Trust Co. v. Commissioner

Docket No. 73785.

United States Board of Tax Appeals

33 B.T.A. 25; 1935 BTA LEXIS 819;

September 10, 1935, Promulgated

Prior to 1931 petitioner purchased from the vendor of houses the contracts for the sale of a number of the houses and lots. In 1931 the purchasers defaulted and petitioner canceled the contracts and took over the houses and lots. The fair market value of the realty so acquired by petitioner was less than the amount of petitioner's unrecovered cost of the sale…

2Cases cited7 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
  3. Bowen v. LansingMichigan Supreme Court · 1901
  4. Walker v. CasgrainMichigan Supreme Court · 1894
  5. Heldt v. CommissionerUnited States Board of Tax Appeals · 1929

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