Searles Real Estate Trust v. Commissioner
United States Board of Tax Appeals
1. ALLOCATION OF COSTS. The petitioner acquired two tracts of land in 1922 for an aggregate purchase price and did not allocate to the respective tracts of land their proportional part of the cost. Immediately after acquirement of the two tracts, petitioner subdivided one of the tracts into town lots and after improving them put them on sale and during the taxable years sold many of them.
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1. ALLOCATION OF COSTS. The petitioner acquired two tracts of land in 1922 for an aggregate purchase price and did not allocate to the respective tracts of land their proportional part of the cost. Immediately after acquirement of the two tracts, petitioner subdivided one of the tracts into town lots and after improving them put them on sale and during the taxable years sold many of them. Held, the aggregate cost of the two tracts should be apportioned in accordance with their respective values at the time of purchase and the profits on the lots sold should be computed accordingly. 2. BAD…
1Opinion of the Court
SEARLES REAL ESTATE TRUST, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Searles Real Estate Trust v. Commissioner
Docket No. 24489.
United States Board of Tax Appeals
25 B.T.A. 1115; 1932 BTA LEXIS 1427;
April 12, 1932, Promulgated
1. ALLOCATION OF COSTS. The petitioner acquired two tracts of land in 1922 for an aggregate purchase price and did not allocate to the respective tracts of land their proportional part of the cost. Immediately after acquirement of the two tracts, petitioner subdivided one of the tracts into town lots and after improving them put them on sale and during…
2Cases cited4 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Searles Real Estate Trust v. CommissionerUnited States Board of Tax Appeals · 1932
- A--C Inv. Asso. v. CommissionerUnited States Board of Tax Appeals · 1931
- D. P. Harris Hardware & Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1931