Lang v. Commissioner
United States Board of Tax Appeals
1. Nonresident alien owners of real estate in the United States consented to its sale in reliance upon the fraudulent representations of their agent. Years later, upon discovery of the fraud, they instituted an action for damages. The trial court awarded damages in an amount equal to the value of the land when sold, plus interest on that amount to the date of the judgment.
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1. Nonresident alien owners of real estate in the United States consented to its sale in reliance upon the fraudulent representations of their agent. Years later, upon discovery of the fraud, they instituted an action for damages. The trial court awarded damages in an amount equal to the value of the land when sold, plus interest on that amount to the date of the judgment. Held, that the total amount constituted damages and the Commissioner erred in including part of it in their gross income, as interest from sources within the United States, under section 211(a) of the Internal Revenue Code.…
1Opinion of the Court
FRANCOIS LANG, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Lang v. Commissioner
Docket Nos. 102740-102758.
United States Board of Tax Appeals
45 B.T.A. 256; 1941 BTA LEXIS 1149;
October 3, 1941, Promulgated
1. Nonresident alien owners of real estate in the United States consented to its sale in reliance upon the fraudulent representations of their agent. Years later, upon discovery of the fraud, they instituted an action for damages. The trial court awarded damages in an amount equal to the value of the land when sold, plus interest on that amount to the date of the…
2Cases cited20 opinions
- Morgan v. CommissionerSupreme Court of the United States · 1940
- Old Colony Railroad v. CommissionerSupreme Court of the United States · 1932
- Seaboard Air Line Railway Co. v. United StatesSupreme Court of the United States · 1923
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- Brooks-Scanlon Corp. v. United StatesSupreme Court of the United States · 1924
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