Legal Opinion

Pennsylvania Co. for Ins. etc. v. Commissioner

United States Board of Tax Appeals

Decided April 24, 1930No. Docket No. 32055Published

TAXABLE TRANSACTION - GROUND RENT. - Where the petitioner sold real estate in Pennsylvania for part cash and for the balance reserved a ground rent which the purchaser agreed to pay and extinguish on or before a fixed date, and which ground rent had a fair market value of the unpaid portion thereof, held that this constituted a taxable transaction in the year the indenture was made.

1Opinion of the Court

PENNSYLVANIA COMPANY FOR INSURANCES ON LIVES AND GRANTING ANNUITIES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Pennsylvania Co. for Ins. etc. v. Commissioner

Docket No. 32055.

United States Board of Tax Appeals

19 B.T.A. 699; 1930 BTA LEXIS 2350;

April 24, 1930, Promulgated

TAXABLE TRANSACTION - GROUND RENT. - Where the petitioner sold real estate in Pennsylvania for part cash and for the balance reserved a ground rent which the purchaser agreed to pay and extinguish on or before a fixed date, and which ground rent had a fair market value of the unpaid portion thereof, held that…

2Cases cited1 opinion

  1. Pennsylvania Co. for Ins. etc. v. CommissionerUnited States Board of Tax Appeals · 1930

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