Walnut Realty Trust v. Commissioner
United States Board of Tax Appeals
1. Upon the evidence, held that a transaction whereby petitioner sold real property was not an installment sale and that petitioner is not entitled to return the profit upon the installment sales basis. 2. The value of real estate equities and notes of third persons received in such transaction determined.
1Opinion of the Court
*852OPINION.
McMahon :
The respondent, in computing the profit from the sale of real estate, used the same values for the notes and real estate acquired as part of the purchase price as were accepted by the parties to the sale, i. e., $82,264 for the notes and $14,000 for the equities ⅛ the real estate. He thus arrived at a profit of $83,043.15 which he included in the petitioner’s gross income for 1923. He refused to allow the petitioner to compute the profit on the installment sales basis, since, by including the notes and the real estate equities in his computation at the values used by the…
2Cited by6 opinions
- Holmes v. CommissionerUnited States Tax Court · 1970
- Funsten v. CommissionerUnited States Board of Tax Appeals · 1941
- Holmes v. CommissionerUnited States Tax Court · 1970
- Kronstadt v. CommissionerUnited States Tax Court · 1954
- Orange Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1941
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