Legal Opinion

Sacks v. Commissioner

United States Board of Tax Appeals

Decided May 18, 1931No. Docket No. 46225Published

Stock acquired by gift before December 31, 1920, and after March 1, 1913, was sold in 1923 for a consideration amounting to less than the value at the date of the gift, which was payable over a period of years.

Read the full summary

Stock acquired by gift before December 31, 1920, and after March 1, 1913, was sold in 1923 for a consideration amounting to less than the value at the date of the gift, which was payable over a period of years. Held that, assuming the transaction to be in any event within section 212(d), Revenue Act of 1926, that section by its express terms applies the installment method to profits and income, and does not authorize the spreading of losses over the period of the installment payments.

1Opinion of the Court

GEORGE P. SACKS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Sacks v. Commissioner

Docket No. 46225.

United States Board of Tax Appeals

23 B.T.A. 307; 1931 BTA LEXIS 1897;

May 18, 1931, Promulgated

Stock acquired by gift before December 31, 1920, and after March 1, 1913, was sold in 1923 for a consideration amounting to less than the value at the date of the gift, which was payable over a period of years. Held that, assuming the transaction to be in any event within section 212(d), Revenue Act of 1926, that section by its express terms applies the installment method to profits and…

2Cases cited1 opinion

  1. Sacks v. CommissionerUnited States Board of Tax Appeals · 1931

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API