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SECURITIES MORTGAGE CO. v. COMMISSIONER

Docket No. 5153-69.

58 T.C. 667 (1972)

SECURITIES MORTGAGE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 24, 1972.

Attorney(s) appearing for the Case

Andrew M. Williams and Alvord B. Rutherford, for the petitioner.

Eugene H. Flood, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency of $175,620 in the petitioner's Federal income tax for the year ending November 30, 1966. The issues to be decided are whether a mortgagee may deduct its loss on the foreclosure of property in the year of the foreclosure sale or in the year in which the redemption rights expire, what burden is placed on the mortgagee to prove the fair market value of property acquired at the foreclosure sale, and what formula...

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