American Offshore, Inc. v. Commissioner
United States Tax Court
Ps on March 23, 1982, sold several vessels and incidental related property for $ 26 million. The purchaser pledged the vessels as security for a $ 16 million first preferred mortgage. Petitioners received $ 15 million and an $ 11 million promissory note subordinated to the first preferred mortgage in payment.
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Ps on March 23, 1982, sold several vessels and incidental related property for $ 26 million. The purchaser pledged the vessels as security for a $ 16 million first preferred mortgage. Petitioners received $ 15 million and an $ 11 million promissory note subordinated to the first preferred mortgage in payment. They reported the transaction as an installment sale under sec. 453. The industry suffered a drastic downturn before any payments were due, and the vessels declined in value to $ 9 million as of February 1983. Held, the subordinated note became totally worthless as of February 28, 1983.…
1Opinion of the Court
AMERICAN OFFSHORE, INC., AMERICAN VESSELS, INC. AND SUBSIDIARIES, AND ZODIAC OFFSHORE, INC. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
American Offshore, Inc. v. Commissioner
Docket No. 15225-86
United States Tax Court
97 T.C. 579; 1991 U.S. Tax Ct. LEXIS 103; 97 T.C. No. 41;
November 25, 1991, Filed
Decision will be entered under Rule 155.
Ps on March 23, 1982, sold several vessels and incidental related property for $ 26 million. The purchaser pledged the vessels as security for a $ 16 million first preferred mortgage. Petitioners received $ 15 million and an $…
2Cases cited45 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- Boehm v. CommissionerSupreme Court of the United States · 1945
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