Lifson v. Commissioner
United States Board of Tax Appeals
One on the cash basis who bought a sheriff's certificate for Minnesota real property in August 1933 and paid the 1933 taxes in 1934, may not deduct the amount as taxes paid in 1934, since such amount is by Minnesota law a lien on May 1, 1933, and is to be regarded as part of the cost of the property.
1Opinion of the Court
OPINION.
Sternhagen :
A deficiency of $4,607.60 in petitioners’ income tax for 1934 was determined. The facts are stipulated.
Sophie Lifson, who with her husband filed a joint return for 1934 on the actual receipts and disbursements basis, bought in August 1933, a sheriff’s certificate of sale of certain foreclosed real property in St. Paul, Minnesota, took possession of the property in October 1933, and recorded the certificate in December 1933. The 1933 Minnesota property taxes amounted to $19,286.27, and she paid this in two equal installments on July 3, 1934, and December 8, 1934. She…
2Cases cited3 opinions
- State v. Northwestern Telephone Exchange Co.Supreme Court of Minnesota · 1900
- Merle-Smith v. Minnesota Iron Co.Supreme Court of Minnesota · 1935
- National Bond & Security Co. v. HopkinsSupreme Court of Minnesota · 1905
3Cited by8 opinions
- Casel v. CommissionerUnited States Tax Court · 1982
- Lifson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1938
- Casel v. CommissionerUnited States Tax Court · 1982
- Chamberlain v. CommissionerUnited States Board of Tax Appeals · 1941
- Coward v. CommissionerUnited States Board of Tax Appeals · 1939
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