GRANGER v. COMMISSIONER
United States Tax Court
Petitioner suffered losses on foreclosure sales of certain properties held subject to mortgage. Petitioner remained liable on the deficiencies in the mortgage obligations and in 1965 paid in full the remaining amounts owed. Held, because petitioner did not prove that the proceeds of the loan for which he undertook the mortgage obligation were used in the acquisition or improvement of the mortgaged property, no deduction is allowed.
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Petitioner suffered losses on foreclosure sales of certain properties held subject to mortgage. Petitioner remained liable on the deficiencies in the mortgage obligations and in 1965 paid in full the remaining amounts owed. Held, because petitioner did not prove that the proceeds of the loan for which he undertook the mortgage obligation were used in the acquisition or improvement of the mortgaged property, no deduction is allowed. Held,further, amounts specifically designated as interest as part of a judgment must be considered as such. Held,further, petitioner has failed to show he suffered…
1Opinion of the Court
THEODORE A. GRANGER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
GRANGER v. COMMISSIONER
Docket No. 9509-74.
United States Tax Court
T.C. Memo 1978-474; 1978 Tax Ct. Memo LEXIS 39; 37 T.C.M. (CCH) 1849-20;
November 28, 1978, Filed
Petitioner suffered losses on foreclosure sales of certain properties held subject to mortgage. Petitioner remained liable on the deficiencies in the mortgage obligations and in 1965 paid in full the remaining amounts owed. Held, because petitioner did not prove that the proceeds of the loan for which he undertook the mortgage obligation were used in the…
2Cases cited15 opinions
- Helvering v. HammelSupreme Court of the United States · 1941
- Kaplan v. CommissionerUnited States Tax Court · 1965
- R. O'Dell & Sons Co. v. Commissioner of Internal Rev.Court of Appeals for the Third Circuit · 1948
- R. O'Dell & Sons Co. v. CommissionerUnited States Tax Court · 1947
- Black v. CommissionerUnited States Board of Tax Appeals · 1941
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