Community Bank v. Commissioner
United States Tax Court
Community Bank made loans to customers secured by real property. Upon default under the loans, the bank foreclosed on the real property securing the loans. The bank then acquired title to the property at foreclosure sales which were conducted in accordance with the provisions of the laws of the State of California. The bank determined that the bid price made by it at the foreclosure sales represented fair market value of the real property acquired.
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Community Bank made loans to customers secured by real property. Upon default under the loans, the bank foreclosed on the real property securing the loans. The bank then acquired title to the property at foreclosure sales which were conducted in accordance with the provisions of the laws of the State of California. The bank determined that the bid price made by it at the foreclosure sales represented fair market value of the real property acquired. Held, for purposes of determining gain or loss under sec. 1.166-6, Income Tax Regs., fair market value of the properties is equal to the bid…
1Opinion of the Court
Community Bank, A Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Community Bank v. Commissioner
Docket No. 2617-72
United States Tax Court
62 T.C. 503; 1974 U.S. Tax Ct. LEXIS 78; 62 T.C. No. 55;
July 9, 1974, Filed
Decision will be entered under Rule 155.
Community Bank made loans to customers secured by real property. Upon default under the loans, the bank foreclosed on the real property securing the loans. The bank then acquired title to the property at foreclosure sales which were conducted in accordance with the provisions of the laws of the State of California. The…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Helvering v. WinmillSupreme Court of the United States · 1938
- Gilberg v. CommissionerUnited States Tax Court · 1971
- Hadley Falls Trust Co. v. United StatesCourt of Appeals for the First Circuit · 1940
- Brown v. United StatesCourt of Appeals for the Third Circuit · 1938
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