Legal Opinion

Securities Mortg. Co. v. Commissioner

United States Tax Court

Decided July 24, 1972No. Docket No. 5153-69Published

In 1966, P, which was in the mortgage loan business, foreclosed the mortgages which it held on two uncompleted apartment projects, and the properties were sold at sheriff's sales. At each sale, P bid the amount, or approximately the amount, of its claim against the debtor and acquired the property for such bid. In connection with one of the properties, the redemption rights did not expire until the succeeding year.

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In 1966, P, which was in the mortgage loan business, foreclosed the mortgages which it held on two uncompleted apartment projects, and the properties were sold at sheriff's sales. At each sale, P bid the amount, or approximately the amount, of its claim against the debtor and acquired the property for such bid. In connection with one of the properties, the redemption rights did not expire until the succeeding year. Held: 1. P was entitled to deduct both of its losses in 1966, even though the redemption rights in connection with one of the properties did not expire until the succeeding year;…

1Opinion of the Court

Securities Mortgage Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Securities Mortg. Co. v. Commissioner

Docket No. 5153-69

United States Tax Court

58 T.C. 667; 1972 U.S. Tax Ct. LEXIS 85;

July 24, 1972, Filed

Decision will be entered under Rule 50.

In 1966, P, which was in the mortgage loan business, foreclosed the mortgages which it held on two uncompleted apartment projects, and the properties were sold at sheriff's sales. At each sale, P bid the amount, or approximately the amount, of its claim against the debtor and acquired the property for such bid. In connection with one…

2Cases cited11 opinions

  1. Elmhurst Cemetery Co. of Joliet v. CommissionerSupreme Court of the United States · 1937
  2. United States v. Joseph G. LeaseCourt of Appeals for the Second Circuit · 1965
  3. In Re Estate of Grace N. Williams, Deceased. Ralph E. Williams v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
  4. Hadley Falls Trust Co. v. United StatesCourt of Appeals for the First Circuit · 1940
  5. Hawkins v. CommissionerUnited States Board of Tax Appeals · 1936

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