Georgia-Florida Land Co. v. Commissioner
United States Board of Tax Appeals
1. The mortgage notes here in question had a fair market value of $70,000. 2. This sale is to be treated as a deferred payment sale not on the installment plan, and the tax for 1924 and 1925 computed accordingly.
1Opinion of the Court
*1255OPINION.
Love:
The soje question for the determination of the Board is whether the tax upon the sales of real estate made by this petitioner in 1924 should be computed upon the basis of “ sales of property on the installment plan,” or “ deferred payment sales not on the installment plan.”
Counsel for the respondent introduced in evidence the petitioner’s tax returns for 1924 and 1925, but made no argument at the hearing and no brief in this case has since been filed for the respondent.
The sales made in 1925 are admitted by the petitioner to have been reported as “ installment sales,” and counsel…
2Cited by10 opinions
- Caldwell v. United StatesCourt of Appeals for the Third Circuit · 1940
- Freeman v. CommissionerUnited States Tax Court · 1961
- Freeman v. CommissionerCourt of Appeals for the Eighth Circuit · 1962
- Freeman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
- Holmes v. CommissionerUnited States Tax Court · 1970
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