Karen Y. Nielsen - Page 9

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            adjudication of the action at bar”.  In light of this posture, we                          
            also sustain petitioner’s evidentiary objections to certain of                             
            the stipulated facts and exhibits.  The contested evidence                                 
            addresses only the reinvestment of the condemnation proceeds, and                          
            while such information would have been relevant to applicability                           
            of sections 1033 and 1034, it has no bearing upon our analysis of                          
            the Relocation Act.                                                                        
            I.  Internal Revenue Code                                                                  
                  As a general rule, the Internal Revenue Code imposes a                               
            Federal tax on the taxable income of every individual.  See sec.                           
            1.  Section 61(a) defines gross income for purposes of                                     
            calculating such taxable income as “all income from whatever                               
            source derived” and further specifies that gains from dealings in                          
            property are included within this broad definition.  See sec.                              
            61(a)(3).  Section 1001(a) then explains that “gain from the sale                          
            or other disposition of property shall be the excess of the                                
            amount realized therefrom over the adjusted basis”.  The basic                             
            principles of tax law would thus require petitioner to recognize                           
            as income the amount, $40,000, by which the $65,000 she received                           
            from the condemnation of her residence exceeded her $25,000                                
            basis.                                                                                     
            II.  Uniform Relocation Assistance Act                                                     
                  The Relocation Act, however, provides contrasting treatment                          
            for certain payments received in conjunction with Government                               






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