A. J. Schwarzler Co. v. Commissioner
United States Board of Tax Appeals
Where a taxpayer owns the fee title to land and erects improvements thereon, the cost of such land and improvements may not be abandoned and written off as a loss while the taxpayer retains title thereto.
1Opinion of the Court
*537OPINION.
Maequette:
The taxpayer claims the right to deduct the cost of a parcel of land purchased in the year 1909', and a foundation wall erected thereon between the years 1909 and 1913, as a loss in the year 1919, upon the ground that the property was abandoned as worthless in that year. The Commissioner denied the loss, upon the ground that it was not a realized loss, as the title to the property was still vested in the taxpayer and no loss had been sustained within the meaning of the law. The taxpayer alleges that it abandoned the property in 1919 and wrote it off on its books as having no…
2Cases cited1 opinion
- East Tennessee Iron & Coal Co. v. WigginCourt of Appeals for the Sixth Circuit · 1895
3Cited by12 opinions
- Beatty v. CommissionerUnited States Tax Court · 1966
- Krauss v. CommissionerUnited States Board of Tax Appeals · 1934
- A. J. Schwarzler Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Beatty v. CommissionerUnited States Tax Court · 1966
- Buckeye Producing Co. v. CommissionerUnited States Board of Tax Appeals · 1928
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