Crane v. Commissioner | |
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Argued December 11, 1946 Decided April 14, 1947 | |
Full case name | Crane v. Commissioner of Internal Revenue |
Citations | 331 U.S. 1 (more) 67 S. Ct. 1047; 91 L. Ed. 1301 |
Case history | |
Prior | 3 T.C. 585 (1944); reversed, 153 F.2d 504 (2d Cir. 1945); cert. granted, 328 U.S. 826 (1946). |
Holding | |
The amount of a nonrecourse mortgage securing property is included in the basis of that property and — upon disposition of the property — the entire remaining balance of the mortgage must be included in the taxpayer's amounts realized. | |
Court membership | |
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Case opinions | |
Majority | Vinson, joined by Black, Reed, Murphy, Rutledge, Burton |
Dissent | Jackson, joined by Frankfurter, Douglas |
Crane v. Commissioner, 331 U.S. 1 (1947), was a case heard before the United States Supreme Court concerning the value, for tax purposes, of inherited property with a nonrecourse mortgage encumbering it.[1] According to Boris I. Bittker, Crane "laid the foundation stone of most tax shelters."
Chief Justice Fred M. Vinson wrote the opinion.