Perkins v. Commissioner of Internal Revenue

These consolidated cases determining deficiencies in income tax for the years 1934, 1935, and 1936, came on to be heard upon the records, briefs, and arguments of counsel; and it appearing that petitioner Katharine H. Perkins received two parcels of real property as gifts and that such parcels had been used by the donors for purposes of residence and pleasure, and that since acquisition thereof by the petitioner Katharine H. Perkins both parcels have been operated for profit; and that petitioners have claimed depreciation upon such property under Sections 113(a) and 114(a) of the Revenue Act…