Legal Opinion

Lockhart v. Commissioner

United States Tax Court

Decided March 18, 1943No. Docket Nos. 108535, 108536Published

The phrase "income which would be returnable," prescribed in section 44 (d) of the Internal Revenue Code as a factor to be used in determining the basis for computing gain or loss upon the satisfaction of installment obligations at less than face value, held to mean the entire profit that would result if the obligations were satisfied in full, and not merely the percentage of such profit that would be taken into account by an individual under section 117 (b) in computing net…

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The phrase "income which would be returnable," prescribed in section 44 (d) of the Internal Revenue Code as a factor to be used in determining the basis for computing gain or loss upon the satisfaction of installment obligations at less than face value, held to mean the entire profit that would result if the obligations were satisfied in full, and not merely the percentage of such profit that would be taken into account by an individual under section 117 (b) in computing net income.

1Opinion of the Court

Blanche A. Lockhart, Petitioner, v. Commissioner of Internal Revenue, Respondent. Arthur M. Lockhart, Petitioner, v. Commissioner of Internal Revenue, Respondent

Lockhart v. Commissioner

Docket Nos. 108535, 108536

United States Tax Court

1 T.C. 804; 1943 U.S. Tax Ct. LEXIS 206;

March 18, 1943, Promulgated

Judgment will be entered for the respondent.

The phrase "income which would be returnable," prescribed in section 44 (d) of the Internal Revenue Code as a factor to be used in determining the basis for computing gain or loss upon the satisfaction of installment obligations at less than face value,…

2Cases cited1 opinion

  1. Lockhart v. CommissionerUnited States Tax Court · 1943

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