Estate of Nissen v. Commissioner
United States Tax Court
The allowable deduction for depreciation of a building owned by an estate is to be apportioned between the estate and the distributees of income of the estate for the years in question, pursuant to sec. 167(g), I.R.C. 1954, despite an allocation to corpus by the executor, pursuant to a provision of the testatrix's will, of additions made in the years in question to a reserve for depreciation of the building.
1Opinion of the Court
Estate of Ida Wray Nissen, Deceased, Wachovia Bank and Trust Company, Executor, Petitioner, v. Commissioner of Internal Revenue, Respondent
Estate of Nissen v. Commissioner
Docket No. 91889
United States Tax Court
41 T.C. 522; 1964 U.S. Tax Ct. LEXIS 162;
January 16, 1964, Filed
Decision will be entered for the respondent.
The allowable deduction for depreciation of a building owned by an estate is to be apportioned between the estate and the distributees of income of the estate for the years in question, pursuant to sec. 167(g), I.R.C. 1954, despite an allocation to corpus by the executor, pursuant…
2Cases cited18 opinions
- Burnet v. HarmelSupreme Court of the United States · 1932
- Helvering v. City Bank Farmers Trust Co.Supreme Court of the United States · 1935
- Wisconsin RR Comm. v. C., B. & QRR CO.Supreme Court of the United States · 1922
- Carasso v. CommissionerUnited States Tax Court · 1960
- Max and Fannie Carasso v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
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