Prendergast v. Commissioner
United States Board of Tax Appeals
In 1925 the decedent sold real estate receiving in payment therefor two 10-year bonds of the vendee secured on the property sold. Held, that the transaction was not an installment sale of real estate with thin the meaning of section 212(d) of the Revenue Act of 1926.
1Opinion of the Court
*1260OPINION.
Smith:
Section 212 (d) of the Revenue Act of 1926, applicable to the year 1925, provides as follows:
Under regulations prescribed by the Commissioner with the approval of the Secretary, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the total profit realized or to be realized when the payment is completed, bears to the total contract price. In the case (1) of a casual sale or other casual disposition of…
2Cited by26 opinions
- Pozzi v. CommissionerUnited States Tax Court · 1967
- Smith v. CommissionerUnited States Tax Court · 1971
- 10-42 Corp. v. CommissionerUnited States Tax Court · 1971
- Consolidated Dry Goods Company v. United StatesDistrict Court, D. Massachusetts · 1960
- Irwin v. CommissionerUnited States Tax Court · 1966
21 more not listed; retrieve them via the Exa API.