Legal Opinion

Webb v. Commissioner

United States Board of Tax Appeals

Decided April 21, 1931No. Docket No. 33070PublishedCited by 2 opinions

Gain from repossession of real estate by cancellation of purchase money note secured by mortgage on the property determined in conformity with Henry Heldt,16 B.T.A. 1035.

1Opinion of the Court

*1250OPINION.

Lansdon:

Each of the parties here has had much difficulty in computing the profit which the partnership realized from the sale and subsequent repossession of a sheep ranch in the circumstances set out above. At some time since 1919 each has occupied the position now defended by the other, but no actual meeting of minds and settlement has deprived this Board of the privilege of deciding the issues in controversy.

*1251In its original return of income for 1919, the partnership treated the sale of the ranch as a completed transaction and reported gain therefrom in the amount of $11,300. More…

2Cited by2 opinions

  1. Title & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1935
  2. Webb v. CommissionerUnited States Board of Tax Appeals · 1931

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