Alvin v. Graff v. Commissioner of Internal Revenue

Having carefully considered the briefs and arguments of the parties in this appeal, taken on undisputed facts, we find ourselves in agreement with the rulings of the Tax Court on the points brought forward to us: that interest reduction payments made by the Department of Housing and Urban Development (HUD) on the taxpayer’s-mortgagee’s behalf pursuant to Section 236 of the National Housing Act, 12 U.S.C. § 1715z-l, are includable in his gross income, and that in the circumstances of this case the Commissioner of Internal Revenue is not equitably estopped by incorrect representations of law…