Carlson v. Commissioner
United States Tax Court
Ps, husband and wife, purchased a fishing vessel (vessel). They financed that purchase by borrowing money from a bank. As security for the loan, Ps granted the bank a mortgage interest in the vessel.
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Ps, husband and wife, purchased a fishing vessel (vessel). They financed that purchase by borrowing money from a bank. As security for the loan, Ps granted the bank a mortgage interest in the vessel. Ps became delinquent in making payments to the bank on the loan, and the bank foreclosed on the vessel, sold it as part of that foreclosure, used the proceeds from that sale to reduce the outstanding principal balance of the loan, and discharged the remaining balance of the loan. As a result, Ps realized capital gain of $ 28,621 and discharge of indebtedness (DOI) income of $ 42,142. Ps excluded…
1Opinion of the Court
RODERICK E. CARLSON AND JEANETTE S. CARLSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Carlson v. Commissioner
No. 12068-99
United States Tax Court
116 T.C. 87; 2001 U.S. Tax Ct. LEXIS 9; 116 T.C. No. 9;
February 23, 2001, Filed
Decision will be entered under Rule 155.
Ps, husband and wife, purchased a fishing vessel (vessel).
They financed that purchase by borrowing money from a bank. As
security for the loan, Ps granted the bank a mortgage interest
in the vessel. Ps became delinquent in making payments to the
bank on the loan, and the bank foreclosed on the vessel, sold it
as part of…
2Cases cited23 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- American Tobacco Co. v. PattersonSupreme Court of the United States · 1982
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Antonides v. CommissionerUnited States Tax Court · 1988
- Borchers v. CommissionerUnited States Tax Court · 1990
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