Salva v. Commissioner
United States Tax Court
R determined deficiencies and additions to tax against Ps in part on account of $ 600,000 of discharge of indebtedness income realized to P's wholly owned S corporation. R contended that the income resulted from cancellation of a mortgage note occurring upon the filing of two satisfactions of mortgage by the S corporation's mortgagee-creditor, releasing two of three properties mortgaged as security for the note and professing discharge of the underlying liability.
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R determined deficiencies and additions to tax against Ps in part on account of $ 600,000 of discharge of indebtedness income realized to P's wholly owned S corporation. R contended that the income resulted from cancellation of a mortgage note occurring upon the filing of two satisfactions of mortgage by the S corporation's mortgagee-creditor, releasing two of three properties mortgaged as security for the note and professing discharge of the underlying liability. R's determinations also took into account $ 43,980 of income flowing from a payment to that S corporation. Ps argued that, under…
1Opinion of the Court
PEDRO AND CONCEPCION SALVA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Salva v. Commissioner
Docket No. 9255-91
United States Tax Court
T.C. Memo 1993-90; 1993 Tax Ct. Memo LEXIS 90; 65 T.C.M. (CCH) 2080;
March 16, 1993, Filed
R determined deficiencies and additions to tax against Ps in part on account of $ 600,000 of discharge of indebtedness income realized to P's wholly owned S corporation. R contended that the income resulted from cancellation of a mortgage note occurring upon the filing of two satisfactions of mortgage by the S corporation's mortgagee-creditor, releasing two…
2Cases cited12 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Recklitis v. CommissionerUnited States Tax Court · 1988
- Fisher v. CommissionerUnited States Tax Court · 1970
- Jackson v. ParkerSupreme Court of Florida · 1943
- Davis v. CommissionerUnited States Tax Court · 1987
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