Interstate Realty Co. v. Commissioner
United States Board of Tax Appeals
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
- United States v. GuinzburgCourt of Appeals for the Second Circuit · 1921
- Staats v. Biograph Co.Court of Appeals for the Second Circuit · 1916
- Indian Refining Co. v. BuhrmanCourt of Appeals for the Second Circuit · 1915
3Cited by4 opinions
- Borall Corp. v. CommissionerUnited States Tax Court · 1946
- Interstate Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Markle v. CommissionerUnited States Tax Court · 1946
- Stavitsky v. CommissionerUnited States Tax Court · 1943