Independent Gravel Co. v. Commissioner
United States Tax Court
The City of Joplin, Mo., issued special tax bills to petitioner in payment for street and sewer improvements which petitioner performed under contracts with the City. These bills were assessed against landowners whose properties were benefited by the improvements and became liens against the properties so benefited. Payment of principal and interest on the bills could be made by the landowner directly to petitioner or could be made to the City which would then forward it.
Read the full summary
The City of Joplin, Mo., issued special tax bills to petitioner in payment for street and sewer improvements which petitioner performed under contracts with the City. These bills were assessed against landowners whose properties were benefited by the improvements and became liens against the properties so benefited. Payment of principal and interest on the bills could be made by the landowner directly to petitioner or could be made to the City which would then forward it. In fact, payment was made directly to petitioner. Held, the special tax bills are governmental obligations and the…
1Opinion of the Court
Forrester, Judge:
Respondent has determined a deficiency in petitioner’s Federal income tax for the year 1962 in the amount of $9,256.55.
Concessions having been made, the only issue remaining for decision is whether interest received on special tax bills of the City of Joplin, Mo., is excludable from gross income under section 108 of the Internal Revenue Code of 1964.1
FINDINGS OF FACT
All facts have been stipulated. The stipulation and exhibits attached thereto are incorporated herein by this reference, and those facts necessary to an understanding of the case are set out below.
Petitioner…
2Cases cited14 opinions
- Commissioner of Internal Revenue v. White's EstateCourt of Appeals for the Second Circuit · 1944
- Bryant v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1940
- Commissioner of Internal Revenue v. PontarelliCourt of Appeals for the Seventh Circuit · 1938
- Pontarelli v. CommissionerUnited States Board of Tax Appeals · 1937
- Riverview State Bank v. CommissionerUnited States Tax Court · 1943
9 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Fairfax County Economic Development Authority v. CommissionerUnited States Tax Court · 1981
- Fairfax County Economic Development Authority v. CommissionerUnited States Tax Court · 1981
- Independent Gravel Co. v. CommissionerUnited States Tax Court · 1971