Eppley v. Commissioner
United States Board of Tax Appeals
The action of the Commissioner in holding that the proceeds derived by the petitioner from the operation of hotels, the possession of which he held under a void contract of sale, constituted taxable income to him, sustained.
1Opinion of the Court
*302OPINION.
Lansdon:
The petitioner concedes that during the periods involved he operated the five hotels which produced the disputed income; also, that he conducted such business as his own, but contends that, inasmuch as the courts subsequently held that the title to such properties was, at all times, in the hands of the Nebraska Hotel Company, it follows, as a matter of law, that all of such proceeds of operation belonged to that corporation. In support of *303his contentions the petitioner has cited numerous decisions of this Board and of the courts holding that income follows ownership and that…
2Cases cited7 opinions
- Weiss v. WeinerSupreme Court of the United States · 1929
- Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930
- Taylor v. RonigerMichigan Supreme Court · 1907
- Carter v. BrownNebraska Supreme Court · 1892
- Millard v. TruaxMichigan Supreme Court · 1889
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Eppley v. CommissionerUnited States Board of Tax Appeals · 1932
- Roberts v. CommissionerUnited States Tax Court · 1948