Rindge Land & Navigation Co. v. Commissioner
United States Board of Tax Appeals
Where the taxpayer caused four reclamation districts to be organized to include only its lands, and used the warrants issued by such districts to pay off mortgages and indebtedness constituting valid liens upon said lands, which warrants created a statutory lien upon said lands for the face value thereof, held, that the transaction resulted in the substitution of one debt for another, without realized gain to the taxpayer.
1Opinion of the Court
*1184OPINION.
Graupner:
The issues relating to allowance of depreciation having been disposed of by stipulation, there remains for our consideration only the question whether the taxpayer made a profit from the refinancing operations. The Commissioner contends that, under section 202 of the Revenue Act of 1918, the taxpayer realized a taxable gain on the transfer of the reclamation works to the four reclamation districts in 1919. The taxpayer alleges three propositions in contravention of the Commissioner’s position: (l)'That the taxpayer and reclamation districts are each component parts of the…
2Cases cited9 opinions
- Southern Pacific Co. v. LoweSupreme Court of the United States · 1918
- Gulf Oil Corp. v. LewellynSupreme Court of the United States · 1918
- Gray v. Reclamation District No. 1500California Supreme Court · 1917
- People Ex Rel. Chapman v. Sacramento Drainage Dist.California Supreme Court · 1909
- People ex rel. Van Loben Sels v. Reclamation District No. 551California Supreme Court · 1897
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3Cited by4 opinions
- Commissioner of Internal Revenue v. Birch Ranch & Oil CoCourt of Appeals for the Ninth Circuit · 1951
- Commissioner of Internal Revenue v. Birch Ranch & Oil CoCourt of Appeals for the Ninth Circuit · 1951
- Motor Products Corp. v. CommissionerUnited States Board of Tax Appeals · 1942
- Rindge Land & Navigation Co. v. CommissionerUnited States Board of Tax Appeals · 1925