Prudential Ins. Co. v. Commissioner
United States Board of Tax Appeals
1. Accrued mortgage interest held to be income to the mortgagee upon its bidding in the property on foreclosure at a price equal to the debt pous interest. 2. Properties on which petitioner had made loans were conveyed to it by the mortgagors in satisfaction of the principal of the debts and unpaid interest.
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1. Accrued mortgage interest held to be income to the mortgagee upon its bidding in the property on foreclosure at a price equal to the debt pous interest. 2. Properties on which petitioner had made loans were conveyed to it by the mortgagors in satisfaction of the principal of the debts and unpaid interest. In the absence of evidence showing the values of such properties it is assumed that they were equal to the amount of the debt and interest, and it is held that the interest constituted income. 3. A lump sum was paid by petitioner for land and improvements thereon. The portion of cost…
1Opinion of the Court
THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Prudential Ins. Co. v. Commissioner
Docket Nos. 56641, 60884, 67238.
United States Board of Tax Appeals
33 B.T.A. 332; 1935 BTA LEXIS 766;
October 30, 1935, Promulgated
1. Accrued mortgage interest held to be income to the mortgagee upon its bidding in the property on foreclosure at a price equal to the debt pous interest. 2. Properties on which petitioner had made loans were conveyed to it by the mortgagors in satisfaction of the principal of the debts and unpaid interest. In the absence of…
2Cases cited1 opinion
- Prudential Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1935