Hancock v. Commissioner
United States Board of Tax Appeals
Prior to December 31, 1921, the petitioner, as vendor, executed contracts for the sale of real estate in California, wherein it was provided that deeds to the property sold would not be delivered until the purchase money had been paid in full.
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Prior to December 31, 1921, the petitioner, as vendor, executed contracts for the sale of real estate in California, wherein it was provided that deeds to the property sold would not be delivered until the purchase money had been paid in full. The purchase money was not fully paid and the deeds were not in fact delivered until subsequent to December 31, 1921. Held, the sales were consummated after December 31, 1921, and petitioner's profits on installment payments received in 1923 are taxable under the capital gain provisions of the Revenue Act of 1921.
1Opinion of the Court
G. ALLAN HANCOCK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Hancock v. Commissioner
Docket No. 36867.
United States Board of Tax Appeals
25 B.T.A. 607; 1932 BTA LEXIS 1501;
February 24, 1932, Promulgated
Prior to December 31, 1921, the petitioner, as vendor, executed contracts for the sale of real estate in California, wherein it was provided that deeds to the property sold would not be delivered until the purchase money had been paid in full. The purchase money was not fully paid and the deeds were not in fact delivered until subsequent to December 31, 1921. Held, the sales were…
2Cases cited3 opinions
- Dahlinger v. CommissionerUnited States Board of Tax Appeals · 1930
- Swift v. CommissionerUnited States Board of Tax Appeals · 1930
- Hancock v. CommissionerUnited States Board of Tax Appeals · 1932