Commissioner of Internal Revenue v. Tufts et al.

Decided May 2, 1983. Harry Andrew Blackmun delivered the opinion of the Court.

Docket 81-1536 · 461 U.S. 300 (1983) · Cited 303 times

Holding

When a taxpayer sells or disposes of property encumbered by a nonrecourse obligation exceeding the fair market value of the property sold, as in this case, the Commissioner may require him to include in the "amount realized" the outstanding amount of the obligation; the fair market value of the property is irrelevant to this calculation.

The Court’s statement of the holding, from the opinion’s syllabus. The syllabus is prepared by the Reporter of Decisions and is not part of the opinion of the Court — read the official opinion for authority.

How the Justices voted

Decided 9–0.

“Concurring” means agreeing with the outcome; any split shown is the Court’s judgment, not each Justice’s reasoning. Source: the Supreme Court Database (Spaeth et al.), Washington University.

Precedents cited

Supreme Court decisions this opinion relies on, ordered by how often it cites each. Cases in our collection link through; others are named.

• Crane v. Commissioner · 331 U.S. 1 (1947)
• National Muffler Dealers Assn., Inc. v. United States · 440 U.S. 472 (1979)
• Commissioner v. South Texas Lumber Co. · 333 U.S. 496 (1948)
• United States v. Correll · 389 U.S. 299 (1967)
• United States v. Kirby Lumber Co · 284 U.S. 1 (1931)
• United States v. Davis · 370 U.S. 65 (1962)
• Commissioner v. Jacobson · 336 U.S. 28 (1949)
• Fulman v. United States · 434 U.S. 528 (1978)
• United States v. Hendler · 303 U.S. 564 (1938)

Cited by

Later Supreme Court opinions in our collection that cite this case.

• United States v. Centennial Savings Bank FSB · 499 U.S. 573 (1991)
• Commissioner v. Indianapolis Power & Light Co. · 493 U.S. 203 (1990)

Official text

Read the official opinion (U.S. Reports, govinfo.gov)

Explore from here

Harry Andrew Blackmun’s profile · All Supreme Court opinions · The Supreme Court

Source: Supreme Court of the United States, slip opinions (1983). Citation count from the Free Law Project’s CourtListener bulk data. Data last verified 2026-07-03. Informational only; verify against the primary source before relying. Not a consumer report (FCRA).