Adda, Inc. v. Commissioner
United States Tax Court
1. On August 5, 1940, the taxpayer purchased a building in New York City and on October 1, 1940, received a real estate tax bill for the year July 1, 1940, to June 30, 1941, which it paid in full.
Read the full summary
1. On August 5, 1940, the taxpayer purchased a building in New York City and on October 1, 1940, received a real estate tax bill for the year July 1, 1940, to June 30, 1941, which it paid in full. The amount paid, held, deductible in full because under New York law there was neither a lien on the property nor personal liability on the seller for payment of the taxes at the time of the taxpayer's acquisition. 2. A taxpayer's right to deduct as interest an amount equal to advance rents from a property, the entire net income from which was payable as "interest" to the seller for a certain period…
1Opinion of the Court
OPINION.
Johnson, Judge:
In determining the deficiency for the fiscal year ended June 30, 1942, the Commissioner recomputed the amount deductible as a net operating loss for the taxable period ended June 30, 1941, making several adjustments not here in issue. Petitioner now asserts a right to two deductions not claimed or allowed, and the issues so raised will be considered.
1. The first involves petitioner’s right to deduct the full amount of $199,660 paid as real estate taxes for the year July 1,1940, to June 30, 1941, on the building which petitioner purchased on August 5, 1940, from the 1514…
2Cases cited8 opinions
- Magruder v. SuppleeSupreme Court of the United States · 1942
- MacGregor v. Johnson-Cowdin-Emmerich, Inc.Court of Appeals for the Second Circuit · 1930
- 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
- Le Roy v. CommissionerUnited States Tax Court · 1944
- 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 by15 opinions
- Pardee v. CommissionerUnited States Tax Court · 1967
- United States v. KoshlandCourt of Appeals for the Ninth Circuit · 1954
- Midler Court Realty, Inc. v. CommissionerUnited States Tax Court · 1974
- Asthmanefrin Co. v. CommissionerUnited States Tax Court · 1956
- Keil Properties, Inc. v. CommissionerUnited States Tax Court · 1955
10 more not listed; retrieve them via the Exa API.