Legal Opinion

Shannonhouse v. Commissioner

United States Tax Court

Decided December 31, 1953No. Docket No. 38718Published

Where taxpayers realized capital gains in 1947 on the sale by warranty deed of income-producing realty, deductions for amounts paid to the purchasers in 1949 in discharge of liabilities for breach of covenants of title to the property are subject to the capital loss provisions of section 117 of the Internal Revenue Code. Arrowsmith v. Commissioner, 344 U.S. 6.

1Opinion of the Court

Estate of James M. Shannonhouse, Deceased, Frances W. Shannonhouse, Executrix, and Frances W. Shannonhouse, Surviving Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent

Shannonhouse v. Commissioner

Docket No. 38718

United States Tax Court

21 T.C. 422; 1953 U.S. Tax Ct. LEXIS 1;

December 31, 1953, Promulgated

Decision will be entered under Rule 50.

Where taxpayers realized capital gains in 1947 on the sale by warranty deed of income-producing realty, deductions for amounts paid to the purchasers in 1949 in discharge of liabilities for breach of covenants of title to the property are…

2Cases cited3 opinions

  1. Arrowsmith v. CommissionerSupreme Court of the United States · 1952
  2. Braznell v. CommissionerUnited States Tax Court · 1951
  3. Shannonhouse v. CommissionerUnited States Tax Court · 1953

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