Legal Opinion

Commissioner v. Tufts

Supreme Court of the United States

Decided May 2, 1983No. 81-1536PublishedCited by 251 opinions

1Opinion of the CourtJustice Blackmun

Over 35 years ago, in Crane v. Commissioner, 331 U. S. 1 (1947), this Court ruled that a taxpayer, who sold property encumbered by a nonrecourse mortgage (the amount of the *302mortgage being less than the property’s value), must include the unpaid balance of the mortgage in the computation of the amount the taxpayer realized on the sale. The case now before us presents the question whether the same rule applies when the unpaid amount of the nonrecourse mortgage exceeds the fair market value of the property sold.

I

On August 1, 1970, respondent Clark Pelt, a builder, and his wholly owned…

2Cases cited18 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
  4. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  5. Commissioner v. JacobsonSupreme Court of the United States · 1949

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3Cited by251 opinions

  1. E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
  2. Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
  3. Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
  4. Estate of Baron v. CommissionerUnited States Tax Court · 1984
  5. Estate of Sydney S. Baron, Sylvia S. Baron, Administratrix, and Sylvia S. Baron v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1986

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