Grand Hotel Co. v. Commissioner
United States Board of Tax Appeals
1. The ownership of property in the State of Washington on March 1 is the event which determines the liability for real estate taxes and fixes the amount, although not ascertainable on that date. 2. Taxes which accrued and became a lien upon real estate in 1921, while petitioner was not the owner of the property, are not deductible in 1922, when petitioner did become the owner of the property, although not due and payable until the latter year.
1Opinion of the Court
*891OPINION.
Black :
Petitioner’s specification of errors was as follows:
1. The Commissioner of Internal Revenue erred in holding the $3,956.76 taxes paid by petitioner in 1922 to be an assessment against Mr. J. E. Ransome, the property holder in 1921.
2. The Commissioner of Internal Revenue erred in holding that the $3,956.76 taxes paid by the petitioner in 1922 became a part of the purchase price of the Grand Hotel Building.
3. The Commissioner of Internal Revenue erred in disallowing as a proper deduction for income-tax purposes taxes paid by the petitioner in 1922, and in assessing $436.72…
2Cited by14 opinions
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- Commissioner of Internal Revenue v. Rust's EstateCourt of Appeals for the Fourth Circuit · 1940
- Texas Coca-Cola Bottling Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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