Heirs of Armstrong v. Tax Court of Puerto Rico

Antonia Armstrong and her husband were the owners of several properties, of which, after her husband’s death, she sold her undivided one-half share, and upon filing her income tax return for each one of the years in which the sales took place, she reported as gain the difference between the price obtained and the fair market value of the respective properties at the time of their allotment to her. The taxpayer having died thereafter, the Treasurer of Puerto Rico notified her heirs sundry deficiencies in connection with said sales 1 as, in his judgment, the gain to be informed should have been…