Morrison v. Commissioner
United States Tax Court
A taxpayer, having elected to report gains from sales of lots on the installment basis, repossessed certain lots after default by the purchaser. By the sale contract's terms the taxpayer retained title for delivery, when all price installments should be paid; default rendered the contract null and void, and released the purchaser from further liability for payment.
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A taxpayer, having elected to report gains from sales of lots on the installment basis, repossessed certain lots after default by the purchaser. By the sale contract's terms the taxpayer retained title for delivery, when all price installments should be paid; default rendered the contract null and void, and released the purchaser from further liability for payment. The Commissioner's determination of a gain by regarding the taxpayer as exchanging the purchaser's installment obligations for the repossessed lot, held, warranted by section 44 (d), Internal Revenue Code, and section 29.44-3,…
1Opinion of the Court
Lucille L. Morrison, Petitioner, v. Commissioner of Internal Revenue, Respondent. Charles R. Morrison, Petitioner, v. Commissioner of Internal Revenue, Respondent
Morrison v. Commissioner
Docket Nos. 17366, 17367
United States Tax Court
12 T.C. 1178; 1949 U.S. Tax Ct. LEXIS 138;
June 30, 1949, Promulgated
Decisions will be entered under Rule 50.
A taxpayer, having elected to report gains from sales of lots on the installment basis, repossessed certain lots after default by the purchaser. By the sale contract's terms the taxpayer retained title for delivery, when all price installments should be…
2Cases cited3 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Morrison v. CommissionerUnited States Tax Court · 1949