Federal Dev. Co. v. Commissioner
United States Board of Tax Appeals
1. GAIN - YEAR RECEIVED. - Petitioner in 1919 sold at a profit certain real estate occupied under lease by a tenant, agreeing to secure the surrender of the premises by the tenant to the purchaser on a certain date in the following year.
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1. GAIN - YEAR RECEIVED. - Petitioner in 1919 sold at a profit certain real estate occupied under lease by a tenant, agreeing to secure the surrender of the premises by the tenant to the purchaser on a certain date in the following year. Fifty thousand dollars of the purchase price was held by the purchaser as a guarantee of the performance of this agreement, the purchaser paying petitioner interest on this sum, the principal being paid over to it in the following year less a small portion representing damage to the purchaser by reason of the tenant holding over for a period after the date…
1Opinion of the Court
*977OPINION.
TRttssell :
The first assignment of error involves a question of law, the correctness of respondent’s action' in including in petitioner’s income for 1919 the sum of $143,967.25, this being the difference between the cost and the sale price less expenses of sale, of certain real estate sold by petitioner in that year to the Boston Federal Reserve Bank. Petitioner contends that $50,000 of this amount does not represent income for 1919 as it was retained by the purchaser as a guarantee of the seller’s obligation to secure the surrender on a certain date of a portion of the premises by a…
2Cited by10 opinions
- Stoner v. CommissionerUnited States Board of Tax Appeals · 1934
- Anderson v. CommissionerUnited States Tax Court · 1961
- Myers v. CommissionerUnited States Board of Tax Appeals · 1934
- Bassett v. CommissionerUnited States Board of Tax Appeals · 1935
- Columbus Brick & Tile Co. v. CommissionerUnited States Board of Tax Appeals · 1932
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