Stimson v. Commissioner
United States Board of Tax Appeals
1. Income derived from the operation of a certain building held to be separate income of petitioner. 2. Loss, measured by the difference between the cost of stock and the amount of liquidating dividends received, allowed as a deduction. 3. Loss alleged to have been sustained on the sale of a tract of land disallowed in the absence of proof of the value of the property at the time of its acquisition by gift.
1Opinion of the Court
*29OPINION.
ARTjndell :
The income in controversy under the first issue is that derived from the operation of the Douglas Block. The petitioner’s contention against taxing him on such income as earnings on his separate property is that the title he held to the property in 1924 was not acquired by devise of his grandfather, but by a community purchase made under an option given by Ezra T. Stimson in 1918 when the property was deeded to his uncle in satisfaction of the mortgage.
The facts of record do not support the contention that the property was acquired by purchase rather than devise. On the…
2Cases cited10 opinions
- United States v. RobbinsSupreme Court of the United States · 1926
- Jacobs v. HoittWashington Supreme Court · 1922
- In re the Estate of BuchananWashington Supreme Court · 1916
- In Re Estate of NiccollsCalifornia Supreme Court · 1912
- In Re the Estate of WarnerCalifornia Supreme Court · 1914
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3Cited by1 opinion
- Stimson v. CommissionerUnited States Board of Tax Appeals · 1931