Arguments
Crane argued that the "property" she acquired upon her husband's death was simply the equity in the land and building, which was the excess of the value of the land and building over the then-existing mortgage (i.e. the equity was zero based on the facts). As a result, she argued that the amount she realized on the sale of the building was her net cash received: $2,500.
The Commissioner of the IRS claimed that the property inherited by Crane was the building and land itself, not merely the equity in the building and land. This position had the merit of comporting with the facts at hand: prior to selling the property, Mrs. Crane had been allowed depreciation deductions in excess of $25,000 on the building. Correspondingly, the Commissioner argued that Crane, through the sale of the building and land, received an amount equal to the net of the cash received in addition to the amount of debt assumed by the purchaser.
Read more about this topic: Crane V. Commissioner
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