Alworth-Washburn Co. v. Commissioner
United States Board of Tax Appeals
Where a corporation sells a group of installment notes, representing the unpaid portions of the purchase price of lands sold by it in a prior year, by blank endorsement to a bank, the amount received by it in said transaction, to the extent that it represents profits realized from the sale of the lands, is reportable as a part of its gross income for the year.
1Opinion of the Court
OPINION.
Lansdon :
The respondent has asserted a deficiency in income tax for the year 1927 in the amount of $19,005.60. The petitioner is a Minnesota corporation with principal office at Duluth. It was organized in 1907, for the purpose of acquiring and selling for profit timber lands in the State of Oregon. In 1926 it sold to the Brooks-Scanlon Lumber Company, a corporation, some 12,440’ acres, “ more or less ” of timber lands, for the contract price of $590,900, payable $100,000 in cash at the time of sale and the balance in five equal annual installments of $98,180, payable successively on…
2Cases cited1 opinion
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
3Cited by5 opinions
- Iowa Guarantee Mortg. Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Alworth-Washburn Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Estate of Broadhead v. CommissionerUnited States Tax Court · 1972
- Thos. Goggan & Bro. v. CommissionerUnited States Board of Tax Appeals · 1941
- Winding River Ranch, Inc. v. CommissionerUnited States Tax Court · 1966