Black v. Commissioner
United States Tax Court
The petitioners sold residential property, a part of the selling price of which was represented by a note secured by a second mortgage upon the property. Later the petitioners relinquished such note for cash and another note which together totaled less than the face amount of the original note.
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The petitioners sold residential property, a part of the selling price of which was represented by a note secured by a second mortgage upon the property. Later the petitioners relinquished such note for cash and another note which together totaled less than the face amount of the original note. Held, that since the fair market value of the property securing the original note was in excess of the indebtedness secured by both the first and second mortgages, the indebtedness due the petitioners was not worthless in whole or in part, and the petitioners are not entitled to a bad debt deduction…
1Opinion of the Court
Leon S. and Dorothy A. Black, Petitioners v. Commissioner of Internal Revenue, Respondent
Black v. Commissioner
Docket No. 5946-66
United States Tax Court
52 T.C. 147; 1969 U.S. Tax Ct. LEXIS 145;
April 23, 1969, Filed
Decision will be entered for the respondent.
The petitioners sold residential property, a part of the selling price of which was represented by a note secured by a second mortgage upon the property. Later the petitioners relinquished such note for cash and another note which together totaled less than the face amount of the original note. Held, that since the fair market value of the…
2Cases cited5 opinions
- H. Beale Rollins and Mary E. Rollins v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1960
- Rollins v. CommissionerUnited States Tax Court · 1959
- O'Bryan Bros. v. COMMISSIONER OF INTERNAL REVENUECourt of Appeals for the Sixth Circuit · 1942
- Raffold Process Corp. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1946
- Black v. CommissionerUnited States Tax Court · 1969