Prudential Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. Accrued mortgage interest held to be income to the mortgagee upon its bidding in the property on foreclosure at a price equal to the debt pous interest. 2. Properties on which petitioner had made loans were conveyed to it by the mortgagors in satisfaction of the principal of the debts and unpaid interest.
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1. Accrued mortgage interest held to be income to the mortgagee upon its bidding in the property on foreclosure at a price equal to the debt pous interest. 2. Properties on which petitioner had made loans were conveyed to it by the mortgagors in satisfaction of the principal of the debts and unpaid interest. In the absence of evidence showing the values of such properties it is assumed that they were equal to the amount of the debt and interest, and it is held that the interest constituted income. 3. A lump sum was paid by petitioner for land and improvements thereon. The portion of cost…
1Opinion of the Court
OPINION.
Aeundell :
The respondent determined deficiencies in income tax for the years and in the amounts as follows:
1927_$22,308.63
1928_ 20, 637. 53
1929_ 275,316.77
1930_ 341,763. 68
*333Petitioner contests only a part of these deficiencies. Several issues were originally raised, some of which petitioner concedes have been settled by decisions of the Supreme Court. One issue, raised by respondent’s answer, relating to a deduction for the mean of reserves for sickness and accident provisions in group insurance policies, has been settled by stipulation and respondent’s concession that the stipulated 4…
2Cases cited2 opinions
- United States Cartridge Co. v. United StatesSupreme Court of the United States · 1932
- Burnet v. National Industrial Alcohol Co.Supreme Court of the United States · 1931
3Cited by6 opinions
- United States v. KoshlandCourt of Appeals for the Ninth Circuit · 1954
- Massachusetts Mutual Life Insurance v. United StatesUnited States Court of Claims · 1984
- Piedmont National Bank of Spartanburg v. United StatesDistrict Court, W.D. South Carolina · 1958
- Piper v. CommissionerUnited States Board of Tax Appeals · 1941
- Prudential Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1935
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