Inaja Land Co. V. Commissioner
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Inaja Land Co. V. Commissioner
Inaja Land Co., Ltd. v. Commissioner, 9 T.C. 727 (1947) was a United States income tax case which discussed whether, and how much, basis the taxpayer could recover to offset a gain from compensation from the government for an easement on his land. HELD: :1. The $50,000 that petitioner received from the City -- for a right of way and an easement on taxpayer's land, and releasing the city from all claims and demands, etc. -- was lost (present) capital rather than lost (future) profits; i.e. it should be chargeable to the capital account for land, rather than treated as taxable income under I.R.C. § 22(a) oday § 61(a)(a). :2. Since, under the circumstances, it was practically impossible to allocate a basis to the easements granted, entirety of the net amount received will be recovered from that basis. Facts In 1928, the taxpayer paid $61,000 for of land on the Owens River. In 1934, the City diverted polluted waters upstream from the taxpayer's property, adversely affecting t ...
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United States Tax Court
The United States Tax Court (in case citations, T.C.) is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 of which provides (in part) that the Congress has the power to "constitute Tribunals inferior to the supreme Court". The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule" ...
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Taxpayer
A taxpayer is a person or organization (such as a company) subject to pay a tax. Modern taxpayers may have an Taxpayer Identification Number, identification number, a reference number issued by a government to Citizenship, citizens or Company, firms. The term "taxpayer" generally characterizes one who pays taxes. A taxpayer is an individual or entity that is obligated to make Payment, payments to Municipality, municipal or government Revenue service, taxation-agencies. Taxes can exist in the form of Income tax, income taxes and/or Property tax, property taxes imposed on owners of real property (such as homes and vehicles), along with many other forms. People may pay taxes when they pay for goods and services which are taxed. The term "taxpayer" often refers to the workforce of a country which pays for government systems and projects through taxation. The taxpayers' money becomes part of the Government spending, public funds, which comprise all money spent or invested by governmen ...
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United States Taxation And Revenue Case Law
United may refer to: Places * United, Pennsylvania, an unincorporated community * United, West Virginia, an unincorporated community Arts and entertainment Films * ''United'' (2003 film), a Norwegian film * ''United'' (2011 film), a BBC Two film Literature * ''United!'' (novel), a 1973 children's novel by Michael Hardcastle Music * United (band), Japanese thrash metal band formed in 1981 Albums * ''United'' (Commodores album), 1986 * ''United'' (Dream Evil album), 2006 * ''United'' (Marvin Gaye and Tammi Terrell album), 1967 * ''United'' (Marian Gold album), 1996 * ''United'' (Phoenix album), 2000 * ''United'' (Woody Shaw album), 1981 Songs * "United" (Judas Priest song), 1980 * "United" (Prince Ital Joe and Marky Mark song), 1994 * "United" (Robbie Williams song), 2000 * "United", a song by Danish duo Nik & Jay featuring Lisa Rowe Television * ''United'' (TV series), a 1990 BBC Two documentary series * ''United!'', a soap opera that aired on BBC One from 1965-19 ...
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Down Payment
Down payment (also called a deposit in British English), is an initial up-front partial payment for the purchase of expensive items/services such as a car or a house. It is usually paid in cash or equivalent at the time of finalizing the transaction. A loan of some sort is then required to finance the remainder of the payment. The main purposes of a down payment is to ensure that the lending institution has enough capital to create money for a loan in fractional reserve banking systems and to recover some of the balance due on the loan in the event that the borrower defaults. In real estate, the asset is used as collateral in order to secure the loan against default. If the borrower fails to repay the loan, the lender is legally entitled to sell the asset and retain enough of the proceeds to repay the remaining balance on the loan, including fees and interest added. A down payment, in this case, reduces the lender's risk to less than the value of the collateral, making it more like ...
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Capital Account
In macroeconomics and international finance, the capital account, also known as the capital and financial account records the net flow of investment transaction into an economy. It is one of the two primary components of the balance of payments, the other being the current account. Whereas the current account reflects a nation's net income, the capital account reflects net change in ownership of national assets. A surplus in the capital account means money is flowing into the country, but unlike a surplus in the current account, the inbound flows effectively represent borrowings or sales of assets rather than payment for work. A deficit in the capital account means money is flowing out of the country, and it suggests the nation is increasing its ownership of foreign assets. The term "capital account" is used with a narrower meaning by the International Monetary Fund (IMF) and affiliated sources. The IMF splits what the rest of the world calls the capital account into two top-leve ...
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Erosion
Erosion is the action of surface processes (such as water flow or wind) that removes soil, rock, or dissolved material from one location on the Earth's crust, and then transports it to another location where it is deposited. Erosion is distinct from weathering which involves no movement. Removal of rock or soil as clastic sediment is referred to as ''physical'' or ''mechanical'' erosion; this contrasts with ''chemical'' erosion, where soil or rock material is removed from an area by dissolution. Eroded sediment or solutes may be transported just a few millimetres, or for thousands of kilometres. Agents of erosion include rainfall; bedrock wear in rivers; coastal erosion by the sea and waves; glacial plucking, abrasion, and scour; areal flooding; wind abrasion; groundwater processes; and mass movement processes in steep landscapes like landslides and debris flows. The rates at which such processes act control how fast a surface is eroded. Typically, physical erosion procee ...
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Flooding
A flood is an overflow of water ( or rarely other fluids) that submerges land that is usually dry. In the sense of "flowing water", the word may also be applied to the inflow of the tide. Floods are an area of study of the discipline hydrology and are of significant concern in agriculture, civil engineering and public health. Human changes to the environment often increase the intensity and frequency of flooding, for example land use changes such as deforestation and removal of wetlands, changes in waterway course or flood controls such as with levees, and larger environmental issues such as climate change and sea level rise. In particular climate change's increased rainfall and extreme weather events increases the severity of other causes for flooding, resulting in more intense floods and increased flood risk. Flooding may occur as an overflow of water from water bodies, such as a river, lake, or ocean, in which the water overtops or breaks levees, resulting in some of t ...
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Fishing
Fishing is the activity of trying to catch fish. Fish are often caught as wildlife from the natural environment, but may also be caught from stocked bodies of water such as ponds, canals, park wetlands and reservoirs. Fishing techniques include hand-gathering, spearing, netting, angling, shooting and trapping, as well as more destructive and often illegal techniques such as electrocution, blasting and poisoning. The term fishing broadly includes catching aquatic animals other than fish, such as crustaceans ( shrimp/ lobsters/crabs), shellfish, cephalopods (octopus/squid) and echinoderms ( starfish/ sea urchins). The term is not normally applied to harvesting fish raised in controlled cultivations ( fish farming). Nor is it normally applied to hunting aquatic mammals, where terms like whaling and sealing are used instead. Fishing has been an important part of human culture since hunter-gatherer times, and is one of the few food production activities that have persisted ...
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Water Pollution
Water pollution (or aquatic pollution) is the contamination of water bodies, usually as a result of human activities, so that it negatively affects its uses. Water bodies include lakes, rivers, oceans, aquifers, reservoirs and groundwater. Water pollution results when contaminants are introduced into these water bodies. Water pollution can be attributed to one of four sources: sewage discharges, industrial activities, agricultural activities, and urban runoff including stormwater. It can be grouped into surface water pollution (either fresh water pollution or marine pollution) or groundwater pollution. For example, releasing inadequately treated wastewater into natural waters can lead to degradation of these aquatic ecosystems. Water pollution can also lead to water-borne diseases for people using polluted water for drinking, bathing, washing or irrigation. Water pollution reduces the ability of the body of water to provide the ecosystem services (such as drinking water) that ...
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James Russell Leech
James Russell Leech (November 19, 1888 – February 5, 1952) was a Republican member of the U.S. House of Representatives from Pennsylvania. Biography J. Russell Leech was born in Ebensburg, Pennsylvania. He attended the Mercersburg Academy, in Mercersburg, Pennsylvania. He graduated from Washington & Jefferson College in Washington, Pennsylvania, in 1911, and from the law department of the University of Pennsylvania at Philadelphia, Pennsylvania in 1915. He was admitted to the bar in 1915 and commenced practice in Ebensburg. During the First World War, he was appointed as a second lieutenant and served with the Seventh Ammunition Train. Leech was elected as a Republican to the Seventieth, Seventy-first, and Seventy-second Congresses and served until his resignation on January 29, 1932, having been appointed a member of the United States Board of Tax Appeals (now the United States Tax Court The United States Tax Court (in case citations, T.C.) is a federal trial court o ...
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Owens River
The Owens River is a river in eastern California in the United States, approximately long.U.S. Geological Survey. National Hydrography Dataset high-resolution flowline dataThe National Map accessed March 17, 2011, It drains into and through the Owens Valley, an arid basin between the eastern slope of the Sierra Nevada and the western faces of the Inyo and White Mountains. The river terminates at the endorheic Owens Lake south of Lone Pine, at the bottom of a watershed. In the early 1900s, the Owens River was the focus of the California Water Wars, fought between the city of Los Angeles and the inhabitants of Owens Valley over the construction of the Los Angeles Aqueduct. Since 1913, the Owens River has been diverted to Los Angeles, causing the ruin of the valley's economy and the drying of Owens Lake. In winter 2006, the Los Angeles Department of Water and Power restored 5% of the pre-aqueduct flow to the river by court order, allowing the Owens River Gorge, the river bed in ...
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Taxable Income
Taxable income refers to the base upon which an income tax system imposes tax. In other words, the income over which the government imposed tax. Generally, it includes some or all items of income and is reduced by expenses and other deductions. The amounts included as income, expenses, and other deductions vary by country or system. Many systems provide that some types of income are not taxable (sometimes called non-assessable income) and some expenditures not deductible in computing taxable income. Some systems base tax on taxable income of the current period, and some on prior periods. Taxable income may refer to the income of any taxpayer, including individuals and corporations, as well as entities that themselves do not pay tax, such as partnerships, in which case it may be called “net profit”. Most systems require that all income Realization (tax), realized (or derived) be included in taxable income. Some systems provide tax exemption#Exempt income, tax exemption for s ...
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