Legal Opinion
Commissioner of Internal Revenue v. Morton Liftin and Sylvia Liftin
Court of Appeals for the Fourth Circuit
Decided April 29, 1963No. 8736_1PublishedCited by 31 opinions
1Opinion of the Court
ALBERT V. BRYAN, Circuit Judge.
Gain was not realized by the respondent taxpayers, the Tax Court has decided, in the discount of certain second mortgage monthly payment notes until after the cost of a note or notes was fully restored, either through payments or foreclosure. The Court rejected the determination of the Commissioner of Internal Revenue that the discount had been received in part by the taxpayers in each of the monthly payments. A petition by the Commissioner for review of this decision is before us.
Our judgment is that the petition should be denied. * The Tax Court’s…
2Cases cited5 opinions
- Doyle v. Mitchell Brothers Co.Supreme Court of the United States · 1918
- Healy v. CommissionerSupreme Court of the United States · 1953
- Hatch v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
- Earl A. Phillips and Dorothy M. Phillips v. William E. Frank, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1961
- Eleanor M. Willhoit and John D. Willhoit v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
3Cited by31 opinions
- McShain v. CommissionerUnited States Tax Court · 1979
- Underhill v. CommissionerUnited States Tax Court · 1966
- Schneider v. CommissionerUnited States Tax Court · 1975
- Inter-City Television Film Corp. v. CommissionerUnited States Tax Court · 1964
- Potter v. CommissionerUnited States Tax Court · 1965
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