Smith v. Commissioner
United States Board of Tax Appeals
In 1929 petitioner purchased two parcels of real estate under land contracts. In one instance petitioner was the original vendee, while in the other he was assignee of the vendee. Under the terms of the contracts he was entitled to possession of the properties and he agreed to enter them for taxation in his own name. After making certain principal payments on the contracts during that year, he defaulted.
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In 1929 petitioner purchased two parcels of real estate under land contracts. In one instance petitioner was the original vendee, while in the other he was assignee of the vendee. Under the terms of the contracts he was entitled to possession of the properties and he agreed to enter them for taxation in his own name. After making certain principal payments on the contracts during that year, he defaulted. In 1935 he surrendered the contracts and his interest in the properties to the vendor in consideration of the vendor's cancellation of his debts under the contracts. Held, that the…
1Opinion of the Court
HAROLD R. SMITH, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Smith v. Commissioner
Docket No. 90142.
United States Board of Tax Appeals
39 B.T.A. 892; 1939 BTA LEXIS 957;
May 18, 1939, Promulgated
In 1929 petitioner purchased two parcels of real estate under land contracts. In one instance petitioner was the original vendee, while in the other he was assignee of the vendee. Under the terms of the contracts he was entitled to possession of the properties and he agreed to enter them for taxation in his own name. After making certain principal payments on the contracts during that…
2Cases cited2 opinions
- Rogers v. CommissionerUnited States Board of Tax Appeals · 1938
- Smith v. CommissionerUnited States Board of Tax Appeals · 1939