Legal Opinion

Williams v. Commissioner

United States Board of Tax Appeals

Decided July 31, 1934No. Docket No. 54087PublishedCited by 1 opinion

INCOME - INSTALLMENT SALES. - Held, that section 44(d) of the Revenue Act of 1928 is applicable to unpaid installment obligations under sales made prior to its enactment and when so applied is constitutional. Estate of Erskine M. Ross,29 B.T.A. 227, followed.

1Opinion of the Court

OPINION.

Leech:

This proceeding seeks redetermination of a deficiency in income tax of $7,906.02 for the period from January 1 to September 3, 1928. The only error assigned is upon respondent’s action in increasing the income of petitioner’s decedent for the period in *1348question by the sum of $62,163.34, as the taxable profit represented in the transmission of an installment obligation of $118,466.64 belonging to petitioner’s decedent at the time of his death on September 3, 1928.

Petitioner is executor of the estate of Francis Williams, deceased, who died September 3, 1928. The decedent on…

2Cases cited5 opinions

  1. United States v. Magnolia Petroleum Co.Supreme Court of the United States · 1928
  2. Taft v. BowersSupreme Court of the United States · 1929
  3. Ross v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Provident Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  5. Crane v. CommissionerUnited States Board of Tax Appeals · 1934

3Cited by1 opinion

  1. Williams v. CommissionerUnited States Board of Tax Appeals · 1934

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