COMMISSIONER V. TUFTS

May 15, 11
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  • If the nonrecourse liability is not paid by the time Summit House is sold or abandoned by PSA, then under Commissioner v. Tufts,/58/ the unpaid amount is .
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  • That reasoning was turned on its head 36 years later in the case Commissioner v. Tufts, 461 U.S. 300 (1983), which addressed the situation that Crane had .
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  • Commissioner v. Tufts. Submitted by boden-davidson on Sun, 2010-02-21 16:30. amount realized. must a taxpayer who sells property encumbered by a nonrecourse .
  • To clarify, for nonrecourse debt fair market value of the property is not taken into consideration1 In Commissioner v. Tufts, the Court pointed out that .
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  • Tufts - Oral Argument. Commissioner v. Tufts - Oral Argument . The Oyez Project, Commissioner v. Tufts , 461 U.S. 300 (1983) .
  • Citation. 461 U.S.300103 S. Ct.1826,75 L. Ed. 2d 863,1983 U.S. 27 click the citation to view the entire case on Brief Fact Summary.
  • Commissioner v. Tufts 95. D. The Exception for Overstated Purchase Price 105. Estate of Franklin v. Commissioner 106. E. Borrowing as a Realization Event .
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  • Commissioner v. Tufts 461 U.S. 300 (1983). Pelt owned a construction company. He took out a loan for $1.8M to build an apartment building (along with some .
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  • 27 posts - 11 authors - Last post: Apr 1, 2010See 2925 Briarpark Ltd. v. Commissioner, 163 F.3d 313 (5th Cir. 1990); Commissioner v. Tufts, 461 U.S. 300 (1983); Treas. Reg. .
  • Results 1 - 30 of 90 . Commissioner v. Tufts (1983) – Page 140: Tufts (P) and others entered into a partnership with Pelt, a builder who previously entered .
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  • Tufts - Oral Argument. Case: Commissioner v. Tufts. Commissioner v. Tufts - Oral Argument . prev next. Commissioner v. Tufts - Oral Argument .
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  • Apr 4, 2007 . Guest v. Commissioner, 77 T.C. 9, 25 (1981); sec. 1.1011-2(a)(3), Income Tax Regs. Both parties cite Commissioner v. Tufts, 461 U.S. 300 .
  • When a nonrecourse debt is canceled in exchange for the property, the transfer is treated as a sale [Commissioner v. Tufts, 461 U.S. 300 (1983); Reg. Sec. .
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  • was a student at Tufts.
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  • Commissioner v. Tufts, 461 U.S. 300 (1983), was a unanimous decision by the United States Supreme Court, which held that when a taxpayer sells or disposes .
  • by CC Day - 1984 - Cited by 1 - Related articles
  • Talk:Commissioner v. Tufts. From Wikipedia, the free encyclopedia. Jump to: navigation, search. WikiProject Law, (Rated Start-class, Low-importance) .
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  • Apr 15, 2011 . It was not until the Court revisited the issue in 1983, in Commissioner v. Tufts , 461 U.S. 300, 307 (1983), that footnote 37 was repudiated, .
  • 75 L.Ed.2d 863 103 S.Ct. 1826 461 U.S. 300 COMMISSIONER OF INTERNAL REVENUE, Petitionerv.John F. TUFTS et al. No. 81-1536. Argued Nov. 29, 1982.
  • Dec 10, 2010 . Commissioner v. Boylston Market Ass'n | Wikipedia Case Brief . Commissioner v. Tufts | e Case Brief | Invispress Case Brief. Corliss v. .
  • For a review of the background of this approach, see Cunningham, "Payment of Debt with Property - The Two Step Analysis after Commissioner v. Tufts," 38 Tax .
  • Jul 9, 2010 . And it is settled that receipt of a loan is not income to the borrower. See Commissioner v. Tufts, 461 U.S. 300, 307, 103 S.Ct. 1826, 1831, .
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  • See Newman, The Resurgence of Footnote 37: Tufts v. Commissioner, 18 Wake Forest L. Rev. 1, 16, n. 116 (1982). There is no potential for similar abuse in .
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  • Mar 13, 2011 . The court rejected the Commissioner's position by distinguishing Commissioner v Tufts. 461 U.S. 300 (1983) (wherein the creditor held a .
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  • 1983 -- Volume 461 -- COMMISSIONER V. TUFTS, 461 U. S. 300 -- United States Supreme Court Cases from Justia & Oyez.
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  • by AM Leamon - 2009 - Cited by 3 - Related articles
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  • To clarify, for nonrecourse debt fair market value of the property is not taken into consideration1 In Commissioner v. Tufts, the Court pointed out that .

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