Graff v. Commissioner
United States Tax Court
P owned an apartment project constructed in accordance with Sec. 236 of the National Housing Act. Under such act, HUD made so-called interest reduction payments on P's behalf. Such payments included part of the interest on the funds borrowed to construct the project.
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P owned an apartment project constructed in accordance with Sec. 236 of the National Housing Act. Under such act, HUD made so-called interest reduction payments on P's behalf. Such payments included part of the interest on the funds borrowed to construct the project. When P was considering whether to construct the project, an official of HUD led him to believe that he would be entitled to deduct the interest payments made by HUD on his behalf, and that he would not be required to include such interest reduction payments in income Held: 1. The interest reduction payments are includable in P's…
1Opinion of the Court
Simpson, Judge:
The Commissioner determined deficiencies in the petitioner’s Federal income taxes of $81,931.43 for 1973 and $1,429.80 for 1974. He also determined an addition to tax of $4,096.57 for 1973 under section 6653(a) of the Internal Revenue Code of 1954,1 but he now concedes that the petitioner is not liable for such addition to tax. After concessions by the parties, the issues for decision are: (1) Whether the interest reduction payments made on behalf of the petitioner under Section 236 of the National Housing Act are taxable to him as income, and whether the portions allocable to…
2Cases cited41 opinions
- Federal Crop Ins. Corp. v. MerrillSupreme Court of the United States · 1947
- Chrysler Corp. v. BrownSupreme Court of the United States · 1979
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- United Housing Foundation, Inc. v. FormanSupreme Court of the United States · 1975
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3Cited by92 opinions
- Harold M. Reynolds v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1988
- Boulez v. CommissionerUnited States Tax Court · 1981
- Alvin v. Graff v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1982
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
87 more not listed; retrieve them via the Exa API.