Legal Opinion

Little v. Commissioner

United States Board of Tax Appeals

Decided December 26, 1930No. Docket No. 21249PublishedCited by 10 opinions

TAX DEDUCTION - INTEREST ON IRRIGATION DISTRICT BONDS. - The petitioner, during the year here under consideration, was the owner of certain real property included in a statutory irrigation district in the State of Idaho. During the year 1923 he paid $4,630.72 assessed against his property as the pro rata part of the interest accruing upon the irrigation district bonds.

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TAX DEDUCTION - INTEREST ON IRRIGATION DISTRICT BONDS. - The petitioner, during the year here under consideration, was the owner of certain real property included in a statutory irrigation district in the State of Idaho. During the year 1923 he paid $4,630.72 assessed against his property as the pro rata part of the interest accruing upon the irrigation district bonds. Held that the said interest assessed as taxes under the Idaho irrigation district statutes was not a tax of a kind tending to increase the value of the property assessed and, therefore, was deductible as a tax under section…

1Opinion of the Court

OPINION.

Trussell:

The respondent has determined a deficiency in the amount of $252.44 in this petitioner’s income tax for the year 1923.

In his return for the year 1923 the petitioner took as a credit, as interest paid, the amount of $4,630.72 assessed against his property as the pro rata part of interest accruing upon bonds of the Emmett Irrigation District, Idaho, the petitioner’s land being included in that irrigation district. The respondent disallowed the deduction *912for the reason that such amount constituted an assessment against a local benefit.

Petitioner contends that the said amount is…

2Cases cited6 opinions

  1. City of Nampa v. Nampa & Meridian Irrigation DistrictIdaho Supreme Court · 1911
  2. Pioneer Irrigation District v. WalkerIdaho Supreme Court · 1911
  3. Colburn v. WilsonIdaho Supreme Court · 1913
  4. Indian Cove Irrigation District v. PrideauxIdaho Supreme Court · 1913
  5. Smith v. Progressive Irrigation DistrictIdaho Supreme Court · 1916

1 more not listed; retrieve them via the Exa API.

3Cited by10 opinions

  1. Descartes v. Tribunal de Contribuciones de Puerto RicoSupreme Court of Puerto Rico · 1950
  2. Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Noble v. CommissionerUnited States Tax Court · 1978
  4. Chapman & Dewey Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Descartes v. Tax Court of Puerto RicoSupreme Court of Puerto Rico · 1950

5 more not listed; retrieve them via the Exa API.

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