Topics: Taxation in the United States, Tax, Partnership, Mortgage loan, Real estate, Mortgage / Pages: 44 (8257 words) / Published: Oct 13th, 2014
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Federal Library
Federal Source Materials
Federal Tax Decisions
American Federal Tax Reports
American Federal Tax Reports (Prior Years)
AFTR 2d Vol. 51
51 AFTR 2d 83-1268-A - 51 AFTR 2d 83-1088
COMM. v. TUFTS, ET AL., 51 AFTR 2d 83-1132 (103 S.Ct. 1826), Code Sec(s)
752; 1001; 1012, (S Ct), 05/02/1983

American Federal Tax Reports

COMM. v. TUFTS, ET AL., Cite as 51 AFTR 2d 83-1132
(103 S.Ct. 1826), Code Sec(s) 752, (S Ct), 05/02/1983
COMMISSIONER of Internal Revenue, PETITIONER v. John F. TUFTS, ET AL.,

Case Information:
[pg. 83-1132]
Code Sec(s):


Court Name:

U.S. Supreme Court,

Docket No.:

No. 81-1536,

Date Decided: 05/02/1983
Prior History:

Court of Appeals for the Fifth Circuit,
2d 81-5660, reversed.


Tax Year(s):

Year 1972.


Decision for Govt.


51 AFTR 2d 83-1132, 461 US 300, 103 S Ct
1826, 75 L Ed 2d 863, 83-1 USTC P 9328.

1. GAIN OR LOSS—Amount realized—obligation assumed, cancelled, reduced, or

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14-10-8 下午7:39

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taken subject to by buyer. Partner who sold interest in partnership that operated apartment complex realized amount equal to outstanding balance of nonrecourse mortgage even though balance exceeded FMV of complex. And Sec. 752(c) didn't limit amount realized to
FMV. That section is directed at transactions between partner and partnership.
Reference(s): 1983 P-H Fed. ¶28,821(10); 31,026(15); 31,162(25).
Code Sec. 1001;

Code Sec. 752;

Code Sec. 1012.

1. Lower court issue not decided on appeal: JUDICIAL PROCEEDINGS—Jurisdiction of courts and related matters—award [pg. 83-1133]of costs and attorney's fees.
Reference(s): 1983 P-H Fed. ¶38,850(1).

Certiorari To The United States Court

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