Darby Inv. Corp. v. Commissioner
United States Tax Court
The petitioner purchased certain Michigan land contracts at substantial discounts of the principal balances due and payable on the face thereof at the time of petitioner's purchase. The contracts were readily marketable and at the time of the petitioner's purchase thereof had fair market values equal to the respective amounts the petitioner paid for them.
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The petitioner purchased certain Michigan land contracts at substantial discounts of the principal balances due and payable on the face thereof at the time of petitioner's purchase. The contracts were readily marketable and at the time of the petitioner's purchase thereof had fair market values equal to the respective amounts the petitioner paid for them. Held, that each monthly payment received by the petitioner on the contracts includes, after deduction of interest, realized discount income in proportion to the difference between the petitioner's cost and the principal balance due upon the…
1Opinion of the Court
OPINION.
Withey, Judge:
Deficiencies have been determined by the respondent in the income of petitioner for the taxable years ended August 31, 1956 and 1957, in the respective amounts of $1,778.46 and $2,427.21.
The only issue is whether respondent has erred in adding to petitioner’s gross income for each year a part of each monthly payment received by petitioner from Michigan land contracts representing partial collection of discount income where petitioner had purchased the vendor’s interest in such contracts at a discount.
All of the stipulated facts are found and we adopt the portion of the…
2Cases cited8 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Wood v. CommissionerUnited States Tax Court · 1955
- Shafpa Realty Corp. v. CommissionerUnited States Board of Tax Appeals · 1927
- Gilbert v. CommissionerUnited States Tax Court · 1946
- Tombari v. CommissionerUnited States Tax Court · 1960
3 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Segel v. CommissionerUnited States Tax Court · 1987
- Underhill v. CommissionerUnited States Tax Court · 1966
- Darby Investment Corporation v. Commissioner or Internal RevenueCourt of Appeals for the Sixth Circuit · 1963
- Inter-City Television Film Corp. v. CommissionerUnited States Tax Court · 1964
- Potter v. CommissionerUnited States Tax Court · 1965
22 more not listed; retrieve them via the Exa API.