Apportioning Basis: Partial Sales, Bargain Sales and the Realization Principle

Authors

Stephen B. Cohen, Georgetown University Law CenterFollow

Document Type

Article

Publication Date

1-1-1997

Abstract

The Internal Revenue Code generally taxes appreciation in the value of property only on realization, defined to mean when property is sold or exchanged. In measuring gain on a sale or exchange, an allowance must be made for the return of capital, referred to as basis. Basis offsets the amount realized-that is, the price received for property-in order to calculate taxable gain.

Publication Citation

Stephen B. Cohen, Apportioning Basis: Partial Sales, Bargain Sales and the Realization Principle, 34 San Diego L. Rev. 1693 (1997)

Scholarly Commons Citation

Cohen, Stephen B., "Apportioning Basis: Partial Sales, Bargain Sales and the Realization Principle" (1997). Georgetown Law Faculty Publications and Other Works. 1589.
https://scholarship.law.georgetown.edu/facpub/1589