Legal Opinion

Commissioner of Internal Revenue v. Boca Ceiga Development Co.

Court of Appeals for the Third Circuit

Decided August 23, 1933No. 5082PublishedCited by 13 opinions

1Opinion of the Court

DAVIS, Circuit Judge.

This petition involves income taxes for the fiscal year ending February 28,19?,6.

On October 30, 1925-, the respondent, the Boca Ceiga Development Company, a Florida real estate corporation, sold a tract of land to one of its stockholders for a gross consideration of $504,000, and received from the purchaser 480 shares of its capital stock, valued at $48,000, as the initial payment. For income tax purposes, the Commissioner of Internal Revenue computed the realized profit upon the installment sale basis as follows:

"Sale Price:

Mortgage…

2Cases cited4 opinions

  1. Commissioner of Internal Revenue v. SA Woods MacH. Co.Court of Appeals for the First Circuit · 1932
  2. Walville Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1929
  3. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1932
  4. Spear & Co. v. HeinerDistrict Court, W.D. Pennsylvania · 1931

3Cited by13 opinions

  1. Esmark, Inc. v. CommissionerUnited States Tax Court · 1988
  2. Helvering v. Edison Bros. Stores, Inc.Court of Appeals for the Eighth Circuit · 1943
  3. Commissioner of Internal Revenue v. Landers CorpCourt of Appeals for the Sixth Circuit · 1954
  4. Commissioner of Internal Revenue v. Rollins Burdick Hunter Co.Court of Appeals for the Seventh Circuit · 1949
  5. Dow Chemical Co. v. KavanaghCourt of Appeals for the Sixth Circuit · 1943

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