Bowen v. Commissioner
United States Board of Tax Appeals
Where a taxpayer mortgagee in 1934 accepted bonds of the Home Owners' Loan Corporation of less face value than her interest in certain mortgages which she had held for more than five, but less than ten, years, the transaction constituted an exchange of capital assets and her deductible loss is limited by the provisions of section 117 of the Revenue Act of 1934.
1Opinion of the Court
JOSEPHINE C. BOWEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Bowen v. Commissioner
Docket No. 87219.
United States Board of Tax Appeals
37 B.T.A. 412; 1938 BTA LEXIS 1046;
February 23, 1938, Promulgated
Where a taxpayer mortgagee in 1934 accepted bonds of the Home Owners' Loan Corporation of less face value than her interest in certain mortgages which she had held for more than five, but less than ten, years, the transaction constituted an exchange of capital assets and her deductible loss is limited by the provisions of section 117 of the Revenue Act of 1934.
John D. Evans,…
2Cases cited1 opinion
- Bowen v. CommissionerUnited States Board of Tax Appeals · 1938