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.
The fair market value of the property at the time of sale was $1,400,000, so they claimed a loss of $55,740. 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.
Read more about this topic: Commissioner V. Tufts
Famous quotes containing the word facts:
“A judge is not supposed to know anything about the facts of life until they have been presented in evidence and explained to him at least three times.”
—Parker, Lord Chief Justice (1900–1972)
“The history of his present majesty, is a history of unremitting injuries and usurpations ... all of which have in direct object the establishment of an absolute tyranny over these states. To prove this, let facts be submitted to a candid world, for the truth of which we pledge a faith yet unsullied by falsehood.”
—Thomas Jefferson (1743–1826)
“Science is built up with facts, as a house is with stones. But a collection of facts is no more a science than a heap of stones is a house.”
—Jules Henri Poincare (1854–1912)