Estate of Lamberth v. Commissioner
United States Tax Court
1. The petitioners' partnership, in 1951, entered into contracts for the sale of 26 mortgaged duplexes. Payments were to be made by the purchasers for a number of years, after which time titles were to be conveyed subject to the balances then due on the mortgage debts. The purchasers were generally war workers having limited assets.
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1. The petitioners' partnership, in 1951, entered into contracts for the sale of 26 mortgaged duplexes. Payments were to be made by the purchasers for a number of years, after which time titles were to be conveyed subject to the balances then due on the mortgage debts. The purchasers were generally war workers having limited assets. The partnership reported these sales on the installment basis in 1951. Sec. 44, I. R. C. 1939. (a) Held, petitioners are bound by their election to report the sales on the installment basis and may not now change to a deferred payment recovery-of-cost basis. (b)…
1Opinion of the Court
Estate of E. P. Lamberth, Deceased, Mary R. Lamberth, Executrix, et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent
Estate of Lamberth v. Commissioner
Docket Nos. 57436, 57437, 57438
United States Tax Court
31 T.C. 302; 1958 U.S. Tax Ct. LEXIS 45;
October 31, 1958, Filed
Decisions will be entered under Rule 50.
1. The petitioners' partnership, in 1951, entered into contracts for the sale of 26 mortgaged duplexes. Payments were to be made by the purchasers for a number of years, after which time titles were to be conveyed subject to the balances then due on the mortgage debts. The…
2Cases cited18 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Burnet v. LoganSupreme Court of the United States · 1931
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Burnet v. S. & L. Building Corp.Supreme Court of the United States · 1933
- S. Nicholas Jacobs and Dolores I. Jacobs v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
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