Steele v. Commissioner
United States Board of Tax Appeals
Taxpayer is not estopped to deny liability in 1931 on income realized in 1923 where a representative of the respondent was fully apprised of the facts and both the taxpayer and respondent's representative relied on a ruling of the respondent's office to the effect that the transaction resulted in no income in 1923.
1Opinion of the Court
*175OPINION.
^Aiítjndell :
The question here is whether the petitioner’s share of the payment of $75,000 in 1931 in partial extinguishment of ground rent reserved in the sale in 1923 is taxable as income in 1931. The Commissioner apparently concedes that the payment is not income in 1931 under the governing revenue act (Revenue Act of 1928) and the decision in Pennsylvania Co. for Insurances on Lives & Granting Annuities, supra, but sets up as an affirmative defense that the taxpayer is estopped to deny a present liability by reason of its failure to pay the tax on the profit when realized in 1923…
2Cases cited2 opinions
- R. H. Stearns Co. v. United StatesSupreme Court of the United States · 1934
- Helvering v. SalvageSupreme Court of the United States · 1936
3Cited by7 opinions
- Ross v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1948
- Grand Central Public Market, Inc. v. United StatesDistrict Court, S.D. California · 1938
- Petersburg Television Corp. v. CommissionerUnited States Tax Court · 1961
- Baker v. Commissioner (A)United States Board of Tax Appeals · 1938
- Grauman's Greater Hollywood Theatre v. CommissionerUnited States Board of Tax Appeals · 1938
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