Woodmar Realty Co. v. Commissioner

Board of Tax Appeals

Woodmar Realty Co. v. Commissioner

17 B.T.A. 88, 1929 BTA LEXIS 2362

CourtUnited States Board of Tax Appeals

DecidedAugust 6, 1929

DocketDocket No. 30984.

StatusPublished

Cited by1 cases

This text of 17 B.T.A. 88 (Woodmar Realty Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Woodmar Realty Co. v. Commissioner, 17 B.T.A. 88, 1929 BTA LEXIS 2362 (bta 1929).

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Opinion

[90]*90OPINION.

Phillips:

The sole question involved is whether the Commissioner properly computed taxable income by including in gross income, at face value, amounts to be paid in the future under contracts of sale made by the petitioner. The evidence leaves no doubt that these contracts had no fair market value or readily realizable market value when received. The Commissioner erroneously included such contracts. Joliet-Norfolk Farm Corporation, 8 B. T. A. 824; Miami Beach Improvement Co., 14 B. T. A. 10.

The deficiency letter sets out the computation of the net income as disclosed by the books of the petitioner and corrected by auditors. Adjustment is then made for taxes paid and deducted on the books, but which are not deductible in computing taxable income. There is then added the item of “ profit deferred.” The taxable income should be computed by eliminating this latter item. In other respects the computation made by the Commissioner is approved.

Decision will be entered wnder Rule 50.

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