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Commissioner v. Tufts : ウィキペディア英語版 | 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. When their basis in the property was $1,455,740 (after their invested capital of $44,212 and deductions taken in the amount of $439,972), they sold it for no consideration other than the assumption of the non-recourse liability.〔''Commissioner v. Tufts'', 461 U.S. 300 (1983).〕 The fair market value of the property at the time of sale was $1,400,000, so they claimed a loss of $55,740.〔Tufts at 300.〕 The Tax Commissioner insisted instead that they actually realized a gain of $400,000; the difference between the principal amount of the debt and their basis.〔
抄文引用元・出典: フリー百科事典『 ウィキペディア(Wikipedia)』 ■ウィキペディアで「Commissioner v. Tufts」の詳細全文を読む
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