
Outline (c) 1997-98 Robert H. Daniels

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1. Income as "gains from dealing in property"
One of largest, most complex code areas
A subset of this is "capital gains"
(gains from dealing in property other than ordinary course of business)
Even tho its not big part of individual income:
10% or less of taxable incomeConcept of "basis"
tax equivalent of "book value"
As adjusted for a variety of itemsCOST RECOVERY of "Adjusted Basis" on sale
Needed to measure the gain element: not gross receipts
idea is that T recovers investment w/o that being taxable income
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2. Measuring gain and loss on property dealings
G/L = Amt Realized ($ and FMV property) - Adj Basis
Code Sec 1001
Weakly drafted: cases center on meaning of "property"
What is the "amount realized" in the payment of debts?
Case: International Freighting
use of appreciated property to pay corporate obligation (employee bonuses) is a realization event, causing tax on difference between cost and market value
IF didn't actually get $ or property -- but it did get "money's worth" in employee services
Is example of court curing the weak language of Sec. 1001. More examples later in context of disposition of debt financed property
Adjusted Basis
basis is the measure of remaining embedded tax cost:
can think of it as previously taxed income, which is not income again when received
Sec. 1016(a) list of plus adjustment factors
realized and recognized defined: Sec. 1001(c)
unless specific exception: typically deferral
realized losses offset income only w/ specific rule
3. Sources of basis
Buy it, die it, gift it or trade it
Cost: Sec. 1012
Cost can be debt-financed cost
limit for seller finance debt
the $1 mm nonrecourse watch tax shelterbasis "bought" when income goes thru tax system
when income is taxed, what's left has a "tax cost""fresh start" basis as of 3/1/13: per case law
Dying basis: Sec. 1014
if inherit property, AB = FMV at date of death: Sec. 1014
so a "step up" (or down) of inherited prop
incentive to hold appreciated property til deathNote community property rule: Sec. 1014(b)(6)
Gift basis
"Carryover" recip takes donor's AB Sec. 1015
Case: Taft v. Bowers
Facts: father gives Dtr appreciated stock in 1921, 1922
Dtr sells in 1923Issue: is dtr taxable on increase in value only while she held
or while father held as wellHolding: the latter
Reasoning: issue is construction of statute
(w/ some constitutional background)
Gift tax was new in 1920If father had sold, his gain would be income to him
Donee not treated as tho purchased at market: would allow father's gain to completely avoid taxException if gift tax paid: 1015(d)(6)
gt on donor's appreciation added to donee's AB
Exception if FMV less than donor's AB
rule: recip has donor's AB for gain; FMV for loss
Trade basis
Tax deferred transactions: g/l not recognized
substitute AB of prop given in as AB of prop rec'd
effect is to preserve taxable gain potentialRE trades, incorporation, much of p'ship involves basis tracking
"Boot": taxable unlike kind prop
used to equalize exchange
AB new = AB old + gain recog - $ rec'd - FMV boot rec'dif convert prop from personal to business use:
AB is lesser of personal AB, or FMV at time of conversion
4. Debt financing and "amount realized":
The Crane, Woodsam, Tufts trilogy
Problem: the weak definition of amount realized
Crane v. Commissioner
Facts:(case not assigned: background)
Mrs Crane inherited bldg worth $262K w/ $262K debt
was during great depression.
no recourse as to her, the heir: "mortgagee in possession"She used estate tax value for depreciation
Seven years later sold for $2,500 net, subject to mortgageIssue: did amt realized include the amount of the debt? Held: yes
note: Mrs. C is being inconsistent: limitations
Reasoning:
Would be absurd and inconsistent to include only equity in amount realized, if debt is is property basis and depreciation
Construe the act as a whole:
not need actual receipt of "money or other property"
"in their narrowest sense"Mrs. C got a benefit in the amount of the mortgage relief, since she had equity above the mortgage
Comment: Crane made tax shelters possible
Deductions based on walkaway debt
and Other People's MoneyWoodsam
Facts: (not assigned) (background)
Mrs. W borrows $ and pledges property.
Debt now exceeds her basis.
Later transfers to Woodsam Co -- basis carryoverWoodsam sells, and argues that basis should have been increased by the excess of debt over AB
i.e. that Mrs. W should have realized gain when she remortgagedAgain, note Tp's inconsistency
Holding: Refinance was not a taxable transaction, regardless of basis
Comment: made tax-free cash possible
Tufts v. Commissioner
(To be discussed in class)
5: Cost recovery: Taxation of Annuities
repeated tack-ons take it up to (w)
Types of purchased payments
Single or many premiums, fixed rate, guaranteed or variable (or inflation-linked)
One or two lives
Immediate or deferred, Wasting or refund feature,
Sec. 72 also applies to government pensions and to many retirement accounts
Divide receipts between income and return of investment
Key is Sec. 72(b): exclusion ratio
investment in contract/expected return
investment: 72(c)(1): cost less prior exclusions
expected return 72(c)(3): life expectancy or "aggregate of amounts receivable as annuity"
(1 - Exclusion Ratio) * current payment = current income
Special rules
If overrecovered, exclusion stops
If underrecovered, deduct on last return, treat as operating loss!
lump sum refunds
allocated to income to extent of cash value buildup Sec. 72(e)(3)
10% penalty tax for premature w/drawal. Sec. 72(q)
done to equalize annuities and retirement plans 72(t)
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6. Relief of Debt Creating Income
Kirby Lumber case: repurchase of bonds at a discount
Sec. 108: not income if Title 11, insolvent, (farm debt)
108(b) reduction of tax attributes: NOL, credits, basis
Zarin
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Build date 3/23/98