Boca Ceiga Dev. Co. v. Commissioner
United States Board of Tax Appeals
1. Upon the evidence, held, that petitioner's books of account were kept and its income-tax returns filed on the basis of actual receipts and disbursements. 2. The respondent's disallowance of amounts alleged to have been accrued as commissions upon real estate sales sustained. 3. Where petitioner received shares of its capital stock as the initial payment upon an installment sale of real estate, it realized no gain in the acquisition of this stock.
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1. Upon the evidence, held, that petitioner's books of account were kept and its income-tax returns filed on the basis of actual receipts and disbursements. 2. The respondent's disallowance of amounts alleged to have been accrued as commissions upon real estate sales sustained. 3. Where petitioner received shares of its capital stock as the initial payment upon an installment sale of real estate, it realized no gain in the acquisition of this stock. Houston Brothers Co.,21 B.T.A. 804, followed.
1Opinion of the Court
BOCA CEIGA DEVELOPMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Boca Ceiga Dev. Co. v. Commissioner
Docket No. 40446.
United States Board of Tax Appeals
25 B.T.A. 941; 1932 BTA LEXIS 1447;
March 22, 1932, Promulgated
1. Upon the evidence, held, that petitioner's books of account were kept and its income-tax returns filed on the basis of actual receipts and disbursements.
2. The respondent's disallowance of amounts alleged to have been accrued as commissions upon real estate sales sustained.
3. Where petitioner received shares of its capital stock as the initial payment…
2Cases cited2 opinions
- Houston Bros. Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Boca Ceiga Dev. Co. v. CommissionerUnited States Board of Tax Appeals · 1932