Legal Opinion

1180 East 63rd Street Bldg. Corp. v. Commissioner

United States Tax Court

Decided March 25, 1949No. Docket No. 15731Published

Petitioner, on accrual basis, in 1936 acquired fee title to a building and part of land on which it was erected, at which time real estate taxes on the property were delinquent; after acquisition further real estate taxes assessed against the property were not paid in full.

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Petitioner, on accrual basis, in 1936 acquired fee title to a building and part of land on which it was erected, at which time real estate taxes on the property were delinquent; after acquisition further real estate taxes assessed against the property were not paid in full. In 1942 delinquent taxes, penalties, and interest exceeded $ 55,000. By agreement between the state's attorney and petitioner, a tax foreclosure suit was brought and property was sold to petitioner's nominee for $ 24,000, from whom petitioner redeemed at the same figure; and, in separate proceedings, petitioners enjoined…

1Opinion of the Court

1180 East 63rd Street Building Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

1180 East 63rd Street Bldg. Corp. v. Commissioner

Docket No. 15731

United States Tax Court

12 T.C. 437; 1949 U.S. Tax Ct. LEXIS 240;

March 25, 1949, Promulgated

Decision will be entered under Rule 50.

Petitioner, on accrual basis, in 1936 acquired fee title to a building and part of land on which it was erected, at which time real estate taxes on the property were delinquent; after acquisition further real estate taxes assessed against the property were not paid in full. In 1942 delinquent taxes,…

2Cases cited15 opinions

  1. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  2. Tyler v. United StatesSupreme Court of the United States · 1930
  3. Commissioner v. JacobsonSupreme Court of the United States · 1949
  4. Helvering v. American Dental Co.Supreme Court of the United States · 1943
  5. Helvering v. Midland Mutual Life InsuranceSupreme Court of the United States · 1937

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