Beek v. Commissioner
United States Tax Court
In 1976, a cash basis partnership acquired real estate for $ 2 million, payable $ 300,000 in cash and $ 1,700,000 in a 10-year wraparound note, bearing interest at 8 1/4 percent.
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In 1976, a cash basis partnership acquired real estate for $ 2 million, payable $ 300,000 in cash and $ 1,700,000 in a 10-year wraparound note, bearing interest at 8 1/4 percent. That year, the partnership made several payments in reduction of the principal and interest due on the note for 1976 and 1977. Held, the portion of the payments attributable to interest for 1976 and 1977 are interest on indebtedness within the meaning of sec. 163(a), I.R.C. 1954, and do not represent additional payments of purchase price. Hudson-Duncan & Co. v. Commissioner, 36 B.T.A. 554 (1937), followed. Held,…
1Opinion of the Court
Barton Beek and Dorothy M. Beek, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Beek v. Commissioner
Docket Nos. 10037-80 -- 10071-80, 10610-80, 10611-80, 14966-80
United States Tax Court
80 T.C. 1024; 1983 U.S. Tax Ct. LEXIS 76; 80 T.C. No. 53;
May 19, 1983, Filed
Decisions will be entered under Rule 155.
In 1976, a cash basis partnership acquired real estate for $ 2 million, payable $ 300,000 in cash and $ 1,700,000 in a 10-year wraparound note, bearing interest at 8 1/4 percent. That year, the partnership made several payments in reduction of the principal and interest due…
2Cases cited22 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Mills v. CommissionerUnited States Tax Court · 1948
- Hogg v. RuffnerSupreme Court of the United States · 1861
- Van Raden v. CommissionerUnited States Tax Court · 1979
- Verbeck v. ClymerCalifornia Supreme Court · 1927
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