Legal Opinion
COMMISSIONER OF INTERNAL REVENUE v. Adda, Inc.
Court of Appeals for the Second Circuit
Decided January 14, 1949No. 35, Docket 20919PublishedCited by 8 opinions
1Opinion of the Court
FRANK, Circuit Judge.
The Commissioner contends that the vendor was personally liable for the real estate taxes before Adda, Inc., the taxpayer, acquired title, and that therefore the taxpayer was not liable for such taxes, and could not properly deduct them, although it paid them. We cannot agree.
We need not here consider whether, in the light of Village of Massapequa Park v. Massapequa Park Villa Sites, 278 N.Y. 28, 15 N.E.2d 177, a resident is ever personally liable for New York City real estate taxes. For assuming, arguendo, that, in the appropriate circumstances, he is, we think that no…
2Cases cited8 opinions
- Magruder v. SuppleeSupreme Court of the United States · 1942
- In re the Application for a Compulsory Accounting in the Estate of AppellAppellate Division of the Supreme Court of the State of New York · 1922
- Commissioner of Internal Revenue v. RoyCourt of Appeals for the Second Circuit · 1945
- Village of Massapequa Park v. Massapequa Park Villa Sites, Inc.New York Court of Appeals · 1938
- In Re the Accounting of the Executors of AppellNew York Court of Appeals · 1922
3 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Pardee v. CommissionerUnited States Tax Court · 1967
- Midler Court Realty, Inc. v. CommissionerUnited States Tax Court · 1974
- Asthmanefrin Co. v. CommissionerUnited States Tax Court · 1956
- Commissioner of Internal Revenue v. Milner Hotels, Inc.Court of Appeals for the Sixth Circuit · 1949
- Hodges v. CommissionerUnited States Tax Court · 1985
3 more not listed; retrieve them via the Exa API.