Legal Opinion

Rindge Land & Navigation Co. v. Commissioner

United States Board of Tax Appeals

Decided November 4, 1925No. Docket No. 3698Published

Where the taxpayer caused four reclamation districts to be organized to include only its lands, and used the warrants issued by such districts to pay off mortgages and indebtedness constituting valid liens upon said lands, which warrants created a statutory lien upon said lands for the face value thereof, held, that the transaction resulted in the substitution of one debt for another, without realized gain to the taxpayer.

1Opinion of the Court

APPEAL OF RINDGE LAND & NAVIGATION CO.

Rindge Land & Navigation Co. v. Commissioner

Docket No. 3698.

United States Board of Tax Appeals

2 B.T.A. 1179; 1925 BTA LEXIS 2143;

November 4, 1925, Decided Submitted August 16, 1925.

Where the taxpayer caused four reclamation districts to be organized to include only its lands, and used the warrants issued by such districts to pay off mortgages and indebtedness constituting valid liens upon said lands, which warrants created a statutory lien upon said lands for the face value thereof, held, that the transaction resulted in the substitution of one debt for…

2Cases cited1 opinion

  1. Rindge Land & Navigation Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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