Legal Opinion

Interstate Realty Co. v. Commissioner

United States Board of Tax Appeals

Decided February 29, 1932No. Docket Nos. 46272, 50981PublishedCited by 4 opinions

Petitioner declared a dividend and discharged the same by distribution of purchase money notes which represented profits from the sale of a subdivision project. Held, that it realized income in the amount of such profits as of the date of distribution.

1Opinion of the Court

*731OPINION.

Lansdon:

In the proceeding at Docket No. 50981 relating to petitioner’s tax liability for the fiscal year 1927, the deficiency is based upon determination of the respondent as follows: The addition to income of $22,152.45, $5,625.55 and $2,199.95 representing, respectively, realization of profit from the collection of deferred payment notes, interest on the notes, and a collection on the principal thereof. The additional tax liability asserted for such year is $4,047.02. At Docket No. 46272, the deficiency for 1928 in the amount of $4,396.82 is based upon respondent’s additions to…

2Cases cited3 opinions

  1. United States v. GuinzburgCourt of Appeals for the Second Circuit · 1921
  2. Staats v. Biograph Co.Court of Appeals for the Second Circuit · 1916
  3. Indian Refining Co. v. BuhrmanCourt of Appeals for the Second Circuit · 1915

3Cited by4 opinions

  1. Borall Corp. v. CommissionerUnited States Tax Court · 1946
  2. Interstate Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  3. Markle v. CommissionerUnited States Tax Court · 1946
  4. Stavitsky v. CommissionerUnited States Tax Court · 1943

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