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Inaja Land Co., Ltd. v. Commissioner, 9 T.C. 727 (1947) was a United States income tax case which discussed whether, and how much, basis the taxpayer could recover to offset a gain from compensation from the government for an easement on his land. HELD: :1. The $50,000 that petitioner received from the City -- for a right of way and an easement on taxpayer's land, and releasing the city from all claims and demands, etc. -- was lost (present) capital rather than lost (future) profits; i.e. it should be chargeable to the capital account for land, rather than treated as taxable income under I.R.C. §22(a) (§61(a) ). :2. Since, under the circumstances, it was practically impossible to allocate a basis to the easements granted, entirety of the net amount received will be recovered from that basis. ==Facts== In 1928, the taxpayer paid $61,000 for of land on a river bank. In 1934, the City diverted polluted waters upstream from the taxpayer's property, adversely affecting the fishing on the taxpayer's property and causing flooding and erosion. The city settled with the taxpayer for $50,000; net of legal fees, taxpayer's gain was $49,000. 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「Inaja Land Co. v. Commissioner」の詳細全文を読む スポンサード リンク
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