Crews v. Commissioner
United States Tax Court
Ps lost their property in a flood and in a subsequent inverse condemnation proceeding were awarded payments for loss of property and prejudgment interest. Held: prejudgment interest is taxable as ordinary income. Held, further, attorneys' fees incurred in the condemnation proceedings are not currently deductible to the extent related to P's condemnation claims; attorneys' fees deductible to extent solely related to interest rate determination.
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Ps lost their property in a flood and in a subsequent inverse condemnation proceeding were awarded payments for loss of property and prejudgment interest. Held: prejudgment interest is taxable as ordinary income. Held, further, attorneys' fees incurred in the condemnation proceedings are not currently deductible to the extent related to P's condemnation claims; attorneys' fees deductible to extent solely related to interest rate determination. Held, further, additions to tax for negligence and substantial understatement of income tax in one case were properly determined by R.
1Opinion of the Court
JAMES V. CREWS AND DOROTHEA G. CREWS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; JOHN B. LEONARD, III AND BETTY B. LEONARD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Crews v. Commissioner
Docket Nos. 14450-91, 19696-91
United States Tax Court
T.C. Memo 1994-64; 1994 Tax Ct. Memo LEXIS 68; 67 T.C.M. (CCH) 2189;
February 22, 1994, Filed
Decision will be entered under Rule 155.
Ps lost their property in a flood and in a subsequent inverse condemnation proceeding were awarded payments for loss of property and prejudgment interest. Held: prejudgment interest is taxable…
2Cases cited13 opinions
- Bixby v. CommissionerUnited States Tax Court · 1972
- Seaboard Air Line Railway Co. v. United StatesSupreme Court of the United States · 1923
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Phelps v. United StatesSupreme Court of the United States · 1927
- Kieselbach v. CommissionerSupreme Court of the United States · 1943
8 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Jack L. Baylin, Tax Matters Partner, Painters Mill Venture v. United StatesCourt of Appeals for the Federal Circuit · 1995