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Income Tax Keyed to Bankman
Woodsam Associates, Inc. v. Commissioner
Citation:198 F.2d 357 (2d Cir. 1952)
In 1934, Mr. and Mrs. Wood formed Woodsam Associates, Inc., Petitioner, and transferred certain property to it in return for capital stock. One piece of property transferred was a house owned by Mrs. Wood for which she had taken out a nonrecourse, second mortgage in the amount of $400,000. Neither Mrs. Wood nor her husband were personally liable on the loan as it was solely secured by the house. Mrs. Wood had purchased the house in 1922 at a total cost of $296,400, which she had partially financed by mortgage debt. The couple claim that when Petitioner sold the house in 1943, it had assumed Mrs. Wood’s basis of $400,000, the value of the second mortgage. However, the Commissioner of Internal Revenue determined that Petitioner had assumed Mrs. Wood’s cost basis of $296,400, the amount she had initially paid to purchase the house in 1922.
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