Hyde v. Comm'r
United States Tax Court
Held: 1. The fair market value of real estate in which Gordon Hyde acquired an interest in 1967 is determined. The assessment and collection of taxes which may be owing by reason of Gordon Hyde's acquisition of an interest in real estate in 1967 are barred by the statute of limitations.
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Held: 1. The fair market value of real estate in which Gordon Hyde acquired an interest in 1967 is determined. The assessment and collection of taxes which may be owing by reason of Gordon Hyde's acquisition of an interest in real estate in 1967 are barred by the statute of limitations. Sec. 6501, I.R.C. 1954. 2. Taxes and interest paid by Gordon Hyde with respect to mortgaged real estate are deductible by him only to the extent they accrued on or after the date on which he acquired an interest in the real estate. 3. A statutory fee paid in connection with the redemption of mortgaged real…
1Opinion of the Court
Fay, Judge:
Respondent determined the following deficiencies in the Federal income tax of petitioners Gordon I. and Janet C. Hyde in these consolidated proceedings:
$23,120.49 CD 05 *<1
46,984.98 H-1 CD 05 00
Concessions having been made, it remains for us to decide: (1) The value of real estate in which Gordon Hyde acquired an interest; (2) whether certain deductions claimed by Gordon Hyde for 1968 under sections 163 and 1641 were excessive; (3) whether a statutory redemption fee is interest within the meaning of section 163; (4) whether Gordon Hyde recognized gain on the sale of certain shares…
2Cases cited8 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Crane v. CommissionerSupreme Court of the United States · 1947
- Court Holding Co. v. CommissionerUnited States Tax Court · 1943
- Holdcroft Transp. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1946
- Court Holding Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1944
3 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Casel v. CommissionerUnited States Tax Court · 1982
- Sharp v. CommissionerUnited States Tax Court · 1980
- Schneider v. CommissionerUnited States Tax Court · 1985
- Commercial Sec. Bank v. CommissionerUnited States Tax Court · 1981
- Regents Park PartnersUnited States Tax Court · 1992
14 more not listed; retrieve them via the Exa API.