Ashlock v. Commissioner

OPINION.

Black, Judge:

This proceeding raises two issues arising out of petitioner’s purchase of property from trustees who continued to receive rental income until February 7, 1946. These two issues may be stated as follows:

1. Were the amounts of rentals paid to the sellers of the property by the lessee, Cessna Aircraft Company, during 1945 and up to February 7,1946, taxable to petitioner because they were applied in part payment of the purchase price which petitioner had agreed to pay for the property ?

2. Is petitioner entitled to have deducted from his gross income in 1946 and 1947,…