Cottage Savings Ass'n v. Commissioner
Cottage Savings Association v. Commissioner, 499 U.S. 554 (1991), was an income tax case before the Supreme Court of the United States. The Court was asked to determine whether the exchange of different participation interests in home mortgages by a savings and loan association was a "disposition of property" under 26 U.S.C. § 1001 of the Internal Revenue Code (since this was the requirement for them to realize, and deduct, their losses on these mortgages). The Court determined that it was a "disposition of property" by making the following three holdings:
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Cottage Savings Ass'n v. Commissioner
Cottage Savings Association v. Commissioner, 499 U.S. 554 (1991), was an income tax case before the Supreme Court of the United States. The Court was asked to determine whether the exchange of different participation interests in home mortgages by a savings and loan association was a "disposition of property" under 26 U.S.C. § 1001 of the Internal Revenue Code (since this was the requirement for them to realize, and deduct, their losses on these mortgages). The Court determined that it was a "disposition of property" by making the following three holdings:
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Cottage Savings Association v. ...... g a "disposition of property."
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743,396,410
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Gain or loss under the Interna ...... of loss here was permissible.
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Rehnquist, Stevens, O'Connor, Scalia, Kennedy, Souter
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Cottage Savings Association v. Commissioner
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Cottage Savings Association v. ...... the following three holdings:
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Cottage Savings Ass'n v. Commissioner
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Cottage Savings Association v. Commissioner of Internal Revenue
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