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.

Six years later, with foreclosure imminent, the property was sold for $3,000 subject to the mortgage and Crane incurred $500 in expenses to complete the sale.

This position had the merit of comporting with the facts at hand: prior to selling the property, Mrs. Crane had been allowed depreciation deductions in excess of $25,000 on the building.

The Court first sided with the Commissioner, agreeing with its construction of the relevant statutory provision that addresses the basis of "property" inherited.

The Court sided with cases repudiating the claim that there must be an actual receipt of money or other property for a taxable gain to result from a transaction.

The reasoning cited, that the taxpayer will treat the property as his own in order to protect his equity investment, has been called the "Crane Economic Benefit Rule."