Bliss v. Commissioner
United States Board of Tax Appeals
1. Interest on an award made as just compensation for property taken through an exercise of the power of condemnation by the city of New York is not interest upon the obligation of a political subdivision of a state within the meaning of section 22(b)(4) of the Revenue Act of 1928. 2. The portion of the award which represents gain to the taxpayer upon the disposition of his property is a part of his gross income for Federal tax purposes. 3. A taxpayer who fails to prove what…
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1. Interest on an award made as just compensation for property taken through an exercise of the power of condemnation by the city of New York is not interest upon the obligation of a political subdivision of a state within the meaning of section 22(b)(4) of the Revenue Act of 1928. 2. The portion of the award which represents gain to the taxpayer upon the disposition of his property is a part of his gross income for Federal tax purposes. 3. A taxpayer who fails to prove what part of the award was invested in other property, the date of acquisition, and the cost of that property has not shown…
1Opinion of the Court
*804OPINION.
Murdock :
Interest on an award made as just compensation for property taken through an exercise of the power of requisition or con*805demnation by the city of New York is not interest upon the obligations of a state, territory, or any political subdivision thereof within the meaning of section 22 (b) (4) of the Revenue Act of 1928. Leo M. Klein, 26 B. T. A. 745; Mary Lincoln Ishami, 26 B. T. A. 1040; United States Trust Co., Executor, v. Anderson, 60 Fed. (2d) 291. Cf. American Viscose Corp., 19 B. T. A. 937; affd., 56 Fed. (2d) 1033; Kansas City Southern Ry. Co., 16 B. T. A. 665; affd.,…
2Cases cited2 opinions
- Evans v. GoreSupreme Court of the United States · 1920
- Miles v. GrahamSupreme Court of the United States · 1925
3Cited by13 opinions
- Baltimore & Ohio R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
- Wolf v. CommissionerUnited States Board of Tax Appeals · 1934
- FRISCHKORN DEV. CO. v. COMMISSIONERUnited States Board of Tax Appeals · 1934
- Knowland v. CommissionerUnited States Board of Tax Appeals · 1933
- Baltimore & Ohio R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
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