Huntington-Redondo Co. v. Commissioner
United States Board of Tax Appeals
After a taxpayer had received and recorded an amount of money as an installment payment on the purchase price of land, it and the vendee agreed in writing before the end of the year that the amount should be applied in satisfaction of the principal and interest on the taxpayer's loans to the vendee, and appropriate entries were accordingly made on the taxpayer's books. Held, the taxpayer may treat the amount on its income tax return in accordance with the final allocation.
1Opinion of the Court
OPINION.
Sternhagen:
The Commissioner determined a deficiency of $1,267,95 in petitioner’s income tax for 1932. He determined that $64,715.97 received by petitioner in 1932 should be regarded as interest $7,704.18 and sale price of land $57,011.79, of which $46,554.69 was profit. The petitioner urges that it correctly treated the amount on its return as $63,314.92 received in repayment of loans and $1,401.05 -as interest thereon. The facts are all presented in a written stipulation.
The petitioner in 1927 sold a tract of land in Los Angeles County, California, to Clifford It. Reid, Inc., for…
2Cases cited1 opinion
- Cardinell v. O'dowdCalifornia Supreme Court · 1872
3Cited by13 opinions
- Rodney v. Comm'rUnited States Tax Court · 1969
- Brown v. CommissionerUnited States Tax Court · 1961
- Bayou Verret Land Co. v. CommissionerUnited States Tax Court · 1969
- Estate of Ratliff v. CommissionerUnited States Tax Court · 1993
- Mason v. United StatesDistrict Court, N.D. California · 1978
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