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Commissioner Vs. Tufts
Cites for this judgment
- US Supreme Court
- May 02, 1983
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U.S. 300 (1983) U.S. Supreme Court Commissioner v. TuftsSearch
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U.S. 300 (1983) Commissioner v. TuftsSearch
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the fair market value of the property is irrelevant to this calculation. Cf. Crane v. CommissionerSearch
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F.2d 1058, reversed. JUSTICE BLACKMUN delivered the opinion of the Court. Over 35 years ago, in Crane v. CommissionerSearch
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Relying on Millar v. CommissionerSearch
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reversed. 651 F.2d 1058 (1981). That court expressly disagreed with the Millar analysis, and, in limiting Crane v. CommissionerSearch
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encumbered by a nonrecourse mortgage of an amount in excess of the property's fair market value. A In Crane v. CommissionerSearch
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See United States v. HendlerSearch
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Cum.Bull. 214. Because the theory on which the rule is based applies equally in this situation, see Millar v. CommissionerSearch
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Mendham Corp. v. CommissionerSearch
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Lutz & Schramm Co. v. CommissionerSearch
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in his basis on the understanding that he had an obligation to repay the full amount. See Woodsam Associates, Inc. v. CommissionerSearch
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for the proceeds upon transfer of the encumbered property. See Page 461 U. S. 314 Estate of Levine v. CommissionerSearch
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Tufts v. CommissionerSearch
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value of the property is irrelevant to this calculation. We find this interpretation to be consistent with Crane v. CommissionerSearch
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U. S. 1 (1947), and to implement the statutory mandate in a reasonable manner. National Muffler Dealers Assn. v. UnitedSearch
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Brief for Petitioner in Crane v. CommissionerSearch
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Gibson Products Co. v. UnitedSearch
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amount realized on the sale of the securing property might be limited to the funds actually received. See Commissioner v. RailSearch
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Fashion Park, Inc. v. CommissionerSearch
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relies on a freeing-of-assets theory to attribute ordinary income to the debtor upon cancellation. See Commissioner v. JacobsonSearch
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amount of debt canceled, and realization of income is deferred until the sale of the property. See Fulton Gold Corp. v. CommissionerSearch
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realizes income just to the extent his assets exceed his liabilities after the cancellation. Lakeland Grocery Co. v. CommissionerSearch
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Cum.Bull. 211, and are entitled to deference as an administrative interpretation of the statute. See Commissioner v. SouthSearch
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however, endorse the Commissioner's view. Indeed, were we writing on a slate clean except for the decision in Crane v. CommissionerSearch
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The new purchaser then takes as his basis the fair market value as of the date of the sale. See, e.g., United States v. DavisSearch
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Gibson Products Co. v. UnitedSearch
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of the mortgage in the proceeds on sale or disposition, see, Page 461 U. S. 320 e.g., Estate of Levine v. CommissionerSearch
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Millar v. CommissionerSearch
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Estate of Delman v. CommissionerSearch
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Peninsula Properties Co., Ltd. v. CommissionerSearch
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the regulations promulgated by the agency charged with interpretation of the statute. National Muffler Dealers Assn. v. UnitedSearch
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Fulman v. UnitedSearch
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U.S. Supreme Court Commissioner v. TuftsSearch
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Cf. Crane v. CommissionerSearch
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Crane v. CommissionerSearch
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A In Crane v. CommissionerSearch
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See Woodsam Associates, Inc. v. CommissionerSearch
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Estate of Levine v. CommissionerSearch
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National Muffler Dealers Assn. v. UnitedSearch
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See Commissioner v. RailSearch
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See Commissioner v. JacobsonSearch
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See Fulton Gold Corp. v. CommissionerSearch
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Lakeland Grocery Co. v. CommissionerSearch
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See Commissioner v. SouthSearch
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United States v. DavisSearch
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Fulman v. UnitedSearch
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