Briarly v. Commissioner
United States Board of Tax Appeals
Petitioners realized taxable income in 1928 from the sale of real estate. They failed to file returns and the collector prepared returns in which he treated the entire profit on the sale as income realized in 1928. Held, without deciding whether the sale was an installment sale, that petitioners may not return the profit on the installment basis. Joe Goldberg,14 B.T.A. 465, followed.
1Opinion of the Court
SARAH BRIARLY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
MARY CUNNINGHAM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Briarly v. Commissioner
Docket Nos. 68677, 68678.
United States Board of Tax Appeals
29 B.T.A. 256; 1933 BTA LEXIS 977;
October 31, 1933, Promulgated
Petitioners realized taxable income in 1928 from the sale of real estate. They failed to file returns and the collector prepared returns in which he treated the entire profit on the sale as income realized in 1928. Held, without deciding whether the sale was an installment sale, that petitioners may…
2Cases cited2 opinions
- Briarly v. CommissionerUnited States Board of Tax Appeals · 1933
- Goldberg v. CommissionerUnited States Board of Tax Appeals · 1928