Chapman v. Commissioner
United States Board of Tax Appeals
In the early part of 1925 the petitioner sold certain real estate owned by him for $70,000, receiving in payment therefor $17,000 in cash and four promissory notes for $13,250 each, payable in one, two, three, and four years from date and which were secured by a first mortgage on the property sold.
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In the early part of 1925 the petitioner sold certain real estate owned by him for $70,000, receiving in payment therefor $17,000 in cash and four promissory notes for $13,250 each, payable in one, two, three, and four years from date and which were secured by a first mortgage on the property sold. Later and during 1925 the petitioner, in part payment of certain other real estate purchased by him about that time, transferred at their face value the two notes having the latest maturity dates. Held that the petitioner is not entitled to report the profit realized from the sale of the property…
1Opinion of the Court
*879OPINION.
Trammell:
The petitioner contends that the sale of January 15, 1925, should be treated for income-tax purposes as on the installment sale basis and that the profit on such sale taxable in 1925 is $11,536.32. He also contends that each of the notes which he transferred at their face value for other property on July 27, 1925, cost him $4,258.46 and that when he transferred them he earned a taxable profit on them of $17,983.08 for 1925 under the provisions of section 204 of the Revenue Act of 1926. He further contends that the second transaction did not take the first one, that is the…
2Cited by4 opinions
- Robinson v. CommissionerUnited States Board of Tax Appeals · 1933
- Iowa Guarantee Mortg. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Chapman v. CommissionerUnited States Board of Tax Appeals · 1930
- Robinson v. CommissionerUnited States Board of Tax Appeals · 1933