Rose v. Commissioner
United States Tax Court
Sec. 483 was enacted on Feb. 26, 1964, and provided for the imputation of interest to certain deferred payments received upon the sale or exchange of property. On Jan. 1, 1964, petitioners sold a motel property on the installment basis with payments to be made over 15 years. The terms of the sale made no provision for interest.
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Sec. 483 was enacted on Feb. 26, 1964, and provided for the imputation of interest to certain deferred payments received upon the sale or exchange of property. On Jan. 1, 1964, petitioners sold a motel property on the installment basis with payments to be made over 15 years. The terms of the sale made no provision for interest. Respondent sought to tax (as interest income) parts of the deferred payments received by petitioners in 1965 and 1966. Held, the application of sec. 483 to a sale completed less than 2 months prior to its enactment was not violative of the due process clause of the…
1Opinion of the Court
David O. and Marjorie P. Rose, Petitioners v. Commissioner of Internal Revenue, Respondent
Rose v. Commissioner
Docket No. 2380-69
United States Tax Court
55 T.C. 28; 1970 U.S. Tax Ct. LEXIS 54;
October 8, 1970, Filed
Decision will be entered for the respondent.
Sec. 483 was enacted on Feb. 26, 1964, and provided for the imputation of interest to certain deferred payments received upon the sale or exchange of property. On Jan. 1, 1964, petitioners sold a motel property on the installment basis with payments to be made over 15 years. The terms of the sale made no provision for interest. Respondent…
2Cases cited26 opinions
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Nichols v. CoolidgeSupreme Court of the United States · 1927
- Welch v. HenrySupreme Court of the United States · 1938
- Milliken v. United StatesSupreme Court of the United States · 1931
- Untermyer v. AndersonSupreme Court of the United States · 1928
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