Crane v. Commissioner
1947 United States Supreme Court case / From Wikipedia, the free encyclopedia
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Crane v. Commissioner, 331 U.S. 1 (1947), was a case heard before the United States Supreme Court concerning the value, for tax purposes, of inherited property with a nonrecourse mortgage encumbering it.[1] According to Boris I. Bittker, Crane "laid the foundation stone of most tax shelters."
Quick Facts Crane v. Commissioner, Argued December 11, 1946 Decided April 14, 1947 ...
Crane v. Commissioner | |
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Argued December 11, 1946 Decided April 14, 1947 | |
Full case name | Crane v. Commissioner of Internal Revenue |
Citations | 331 U.S. 1 (more) 67 S. Ct. 1047; 91 L. Ed. 1301 |
Case history | |
Prior | 3 T.C. 585 (1944); reversed, 153 F.2d 504 (2d Cir. 1945); cert. granted, 328 U.S. 826 (1946). |
Holding | |
The amount of a nonrecourse mortgage securing property is included in the basis of that property and — upon disposition of the property — the entire remaining balance of the mortgage must be included in the taxpayer's amounts realized. | |
Court membership | |
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Case opinions | |
Majority | Vinson, joined by Black, Reed, Murphy, Rutledge, Burton |
Dissent | Jackson, joined by Frankfurter, Douglas |
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Wikisource has original text related to this article:
Chief Justice Fred M. Vinson wrote the opinion.