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COMMISSIONER v. TUFTS

No. 81-1536.

461 U.S. 300 (1983)

103 S.Ct. 1826

75 L.Ed.2d 863

COMMISSIONER OF INTERNAL REVENUE v. TUFTS ET AL.

Supreme Court of United States.

Decided May 2, 1983.

Attorney(s) appearing for the Case

Stuart A. Smith argued the cause for petitioner. With him on the briefs were Solicitor General Lee, Assistant Attorney General Archer, Michael L. Paup, and Gilbert S. Rothenberg.

Ronald M. Mankoff argued the cause for respondents. With him on the brief was Charles D. Pulman.*

JUSTICE BLACKMUN delivered the opinion of the Court.

Over 35 years ago, in Crane v. Commissioner, 331 U.S. 1 (1947), this Court ruled that a taxpayer, who sold property encumbered by a nonrecourse mortgage (the amount of the

[461 U.S. 302]
mortgage being less than the property's value), must include the unpaid balance of the mortgage in the computation of the amount the taxpayer realized on...

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