St. Denis Sec. Co. v. Commissioner
United States Tax Court
In 1947 petitioner held property subject to the debts of its president, who was adjudged bankrupt. Petitioner paid to the trustee in bankruptcy $7,929.02. Held: Such payment was for the purpose of protecting petitioner's title to the property and as such was in the nature of a nondeductible capital expenditure.
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In 1947 petitioner held property subject to the debts of its president, who was adjudged bankrupt. Petitioner paid to the trustee in bankruptcy $7,929.02. Held: Such payment was for the purpose of protecting petitioner's title to the property and as such was in the nature of a nondeductible capital expenditure. Held further: 1. Useful life and basis of petitioner's brick veneer building, furniture and fixtures determined. 2. Rental income for 1947, gain from sale of land in 1948, and charitable deduction for 1949 determined. 3. Petitioner did not realize gain from sale of land in 1947. 4.…
1Opinion of the Court
The Saint Denis Securities Company, Inc. v. Commissioner.
St. Denis Sec. Co. v. Commissioner
Docket Nos. 36486, 55213.
United States Tax Court
T.C. Memo 1957-247; 1957 Tax Ct. Memo LEXIS 5; 16 T.C.M. (CCH) 1138; T.C.M. (RIA) 57247;
December 31, 1957
In 1947 petitioner held property subject to the debts of its president, who was adjudged bankrupt. Petitioner paid to the trustee in bankruptcy $7,929.02. Held: Such payment was for the purpose of protecting petitioner's title to the property and as such was in the nature of a nondeductible capital expenditure.
Held further:
1. Useful life and basis of…
2Cases cited5 opinions
- Stanley v. JonesSupreme Court of Louisiana · 1942
- Parkersburg Iron & Steel Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Cohen v. CommissionerUnited States Tax Court · 1955
- Letz v. CommissionerUnited States Board of Tax Appeals · 1941
- Pratt v. CommissionerUnited States Board of Tax Appeals · 1927