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Commissioner V. Tufts
''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 of property encumbered by a nonrecourse obligation exceeding the fair market value of the property sold, the Commissioner of Internal Revenue may require him to include in the “amount realized” the outstanding amount of the obligation; the fair market value of the property is irrelevant to this calculation. Facts Taxpayers borrowed $1,851,500 on a non-recourse basis to build an apartment complex. Later, they sold the complex for no consideration other than the assumption of the non-recourse liability. At the time of the sale, the fair market value of the property was $1,400,000, and their basis in the property was $1,455,740 (i.e.: the $1,851,500 which they borrowed, plus their invested capital of $44,212, minus deductions taken in the amount of $439,972.) The taxpayers argued that their tax consequences should equ ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Lawyers' Edition
The ''United States Supreme Court Reports, Lawyers' Edition'', or ''Lawyers' Edition'' (L. Ed. and L. Ed. 2d in case citations) is an unofficial reporter of Supreme Court of the United States opinions. The ''Lawyers' Edition'' was established by the Lawyers Cooperative Publishing Company of Rochester, New York in 1882, and features coverage of Supreme Court decisions going back to 1790. The first ''Lawyers' Edition'' series corresponds to the official '' United States Reports'' from volume 1 to volume 351, whereas the second series contains cases starting from the official reporter volume 352. It is currently published by LexisNexis. The ''Lawyers' Edition'' differs from the official reporter in that the editors write headnotes and case summaries, as well as provide annotations to some cases, and decisions are published far in advance of the official reporter. As such, it is similar to West's unofficial '' Supreme Court Reporter'' (S. Ct.). ''Lawyers' Edition'' case report ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Apartment
An apartment (American English), or flat (British English, Indian English, South African English), is a self-contained housing unit (a type of residential real estate) that occupies part of a building, generally on a single story. There are many names for these overall buildings, see below. The housing tenure of apartments also varies considerably, from large-scale public housing, to owner occupancy within what is legally a condominium ( strata title or commonhold), to tenants renting from a private landlord (see leasehold estate). Terminology The term ''apartment'' is favored in North America (although in some cities ''flat'' is used for a unit which is part of a house containing two or three units, typically one to a floor). In the UK, the term ''apartment'' is more usual in professional real estate and architectural circles where otherwise the term ''flat'' is used commonly, but not exclusively, for an apartment on a single level (hence a 'flat' apartment). In some ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
1983 In United States Case Law
The year 1983 saw both the official beginning of the Internet and the first mobile cellular telephone call. Events January * January 1 – The migration of the ARPANET to TCP/IP is officially completed (this is considered to be the beginning of the true Internet). * January 24 – Twenty-five members of the Red Brigades are sentenced to life imprisonment for the 1978 murder of Italian politician Aldo Moro. * January 25 ** High-ranking Nazi war criminal Klaus Barbie is arrested in Bolivia. ** IRAS is launched from Vandenberg AFB, to conduct the world's first all-sky infrared survey from space. February * February 2 – Giovanni Vigliotto goes on trial on charges of polygamy involving 105 women. * February 3 – Prime Minister of Australia Malcolm Fraser is granted a double dissolution of both houses of parliament, for elections on March 5, 1983. As Fraser is being granted the dissolution, Bill Hayden resigns as leader of the Australian Labor Party, and in the subse ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Taxation And Revenue Case Law
United may refer to: Places * United, Pennsylvania, an unincorporated community * United, West Virginia, an unincorporated community Arts and entertainment Films * ''United'' (2003 film), a Norwegian film * ''United'' (2011 film), a BBC Two film Literature * ''United!'' (novel), a 1973 children's novel by Michael Hardcastle Music * United (band), Japanese thrash metal band formed in 1981 Albums * ''United'' (Commodores album), 1986 * ''United'' (Dream Evil album), 2006 * ''United'' (Marvin Gaye and Tammi Terrell album), 1967 * ''United'' (Marian Gold album), 1996 * ''United'' (Phoenix album), 2000 * ''United'' (Woody Shaw album), 1981 Songs * "United" (Judas Priest song), 1980 * "United" (Prince Ital Joe and Marky Mark song), 1994 * "United" (Robbie Williams song), 2000 * "United", a song by Danish duo Nik & Jay featuring Lisa Rowe Television * ''United'' (TV series), a 1990 BBC Two documentary series * ''United!'', a soap opera that aired on BBC One from 1965-19 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Supreme Court Cases
This page serves as an index of lists of United States Supreme Court cases. The United States Supreme Court is the highest federal court of the United States. By Chief Justice Court historians and other legal scholars consider each Chief Justice of the United States who presides over the Supreme Court of the United States to be the head of an era of the Court. These lists are sorted chronologically by Chief Justice and include most major cases decided by the Court. * Jay, Rutledge, and Ellsworth Courts (October 19, 1789 – December 15, 1800) * Marshall Court (February 4, 1801 – July 6, 1835) * Taney Court (March 28, 1836 – October 12, 1864) * Chase Court (December 15, 1864 – May 7, 1873) * Waite Court (March 4, 1874 – March 23, 1888) * Fuller Court (October 8, 1888 – July 4, 1910) * White Court (December 19, 1910 – May 19, 1921) * Taft Court (July 11, 1921 – February 3, 1930) * Hughes Court (February 24, 1930 – Ju ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Taxation In The United States
The United States of America has separate federal, state, and local governments with taxes imposed at each of these levels. Taxes are levied on income, payroll, property, sales, capital gains, dividends, imports, estates and gifts, as well as various fees. In 2020, taxes collected by federal, state, and local governments amounted to 25.5% of GDP, below the OECD average of 33.5% of GDP. The United States had the seventh-lowest tax revenue-to-GDP ratio among OECD countries in 2020, with a higher ratio than Mexico, Colombia, Chile, Ireland, Costa Rica, and Turkey. Taxes fall much more heavily on labor income than on capital income. Divergent taxes and subsidies for different forms of income and spending can also constitute a form of indirect taxation of some activities over others. For example, individual spending on higher education can be said to be "taxed" at a high rate, compared to other forms of personal expenditure which are formally recognized as investments. Taxes are i ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
List Of United States Supreme Court Cases, Volume 331
This is a list of all the United States Supreme Court cases from volume 331 of the ''United States Reports The ''United States Reports'' () are the official record ( law reports) of the Supreme Court of the United States. They include rulings, orders, case tables (list of every case decided), in alphabetical order both by the name of the petitioner ...'': External links {{SCOTUSCases, 331 1947 in United States case law ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Crane V
Crane or cranes may refer to: Common meanings * Crane (bird), a large, long-necked bird * Crane (machine), industrial machinery for lifting ** Crane (rail), a crane suited for use on railroads People and fictional characters * Crane (surname), including a list of people and fictional characters with the surname * Crane (given name), a list of people Places Barbados * The Crane, Saint Philip, Barbados United Kingdom * River Crane, Dorset * River Crane, London, a small river of London, branch to the Thames United States * Crane, Indiana, a town * Crane, Missouri, a town * Crane, Montana, a census-designated place and unincorporated community * Crane, Oregon, a census-designated place and unincorporated community * Crane County, Texas ** Crane, Texas, a city and the county seat * Crane, Virginia, an unincorporated community * Crane, Washington, an unincorporated community * Crane Creek (other) * Crane Beach, Ipswich, Massachusetts * Crane Island (Washington) ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Commissioner Of Internal Revenue
The Commissioner of Internal Revenue is the head of the Internal Revenue Service (IRS), an agency within the United States Department of the Treasury. The office of Commissioner was created by Congress as part of the Revenue Act of 1862. Section 7803 of the Internal Revenue Code provides for the appointment of a Commissioner of Internal Revenue to administer and supervise the execution and application of the internal revenue laws. The Commissioner is appointed by the President of the United States, with the consent of the U.S. Senate, for a five-year term. Douglas O’Donnell became the current and Acting Commissioner of Internal Revenue after Charles P. Rettig's term as Commissioner ended on November 12, 2022. Responsibilities The Commissioner's duties include administering, managing, conducting, directing, and supervising "the execution and application of the internal revenue laws or related statutes and tax conventions to which the United States is a party" and advisin ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Tax Court
The United States Tax Court (in case citations, T.C.) is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 of which provides (in part) that the Congress has the power to "constitute Tribunals inferior to the supreme Court". The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Fair Market Value
The fair market value of property is the price at which it would change hands between a willing and informed buyer and seller. The term is used throughout the Internal Revenue Code, as well as in bankruptcy laws, in many state laws, and by several regulatory bodies. In litigation in many jurisdictions in the United States the fair market value is determined at a hearing. In certain jurisdictions, the courts are required to hold fair market hearings, even if the borrowers or the loans guarantors waived their rights to such a hearing in the loan documents. Definition United States The fair market value is the price at which property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts. ''United States v. Cartwright'', 411 U. S. 546, 93 S. Ct. 1713, 1716-17, 36 L. Ed. 2d 528, 73-1 U.S. Tax Cas. ( CCH) ¶ 12,926 (1973) (quoting from U.S. Treasury regulations rela ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Nonrecourse Obligation
Nonrecourse debt or a nonrecourse loan (sometimes hyphenated as non-recourse) is a secured loan (debt) that is secured by a pledge of collateral, typically real property, but for which the borrower is not personally liable. If the borrower defaults, the lender can seize and sell the collateral, but if the collateral sells for less than the debt, the lender cannot seek that deficiency balance from the borrower—its recovery is limited only to the value of the collateral. Thus, nonrecourse debt is typically limited to 50% or 60% loan-to-value ratios, so that the property itself provides "overcollateralization" of the loan. The incentives for the parties are at an intermediate position between those of a full recourse secured loan and a totally unsecured loan. While the borrower is in first loss position, the lender also assumes significant risk, so the lender must underwrite the loan with much more care than in a full recourse loan. This typically requires that the lender have sign ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
