Koshland v. Commissioner
United States Tax Court
Adjusted Gross Income -- Deduction Attributable to Rents -- Interest. -- The petitioner, prior to the taxable years, borrowed money on unsecured notes to purchase interests in rental property.
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Adjusted Gross Income -- Deduction Attributable to Rents -- Interest. -- The petitioner, prior to the taxable years, borrowed money on unsecured notes to purchase interests in rental property. Held, that the interest paid on the notes in the taxable years shall be deducted from gross income in arriving at adjusted gross income as a deduction allowed by section 23 which is "attributable" to property held for the production of rents within the meaning and intent of subsection (4) of section 22 (n) of the Code.
1Opinion of the Court
Corinne S. Koshland, Petitioner v. Commissioner of Internal Revenue, Respondent
Koshland v. Commissioner
Docket Nos. 38668, 39877
United States Tax Court
19 T.C. 860; 1953 U.S. Tax Ct. LEXIS 238;
February 17, 1953, Promulgated
Decisions will be entered for the respondent.
Adjusted Gross Income -- Deduction Attributable to Rents -- Interest. -- The petitioner, prior to the taxable years, borrowed money on unsecured notes to purchase interests in rental property. Held, that the interest paid on the notes in the taxable years shall be deducted from gross income in arriving at adjusted gross income as a…
2Cases cited1 opinion
- Koshland v. CommissionerUnited States Tax Court · 1953