Legal Opinion

Crayton v. Commissioner

United States Board of Tax Appeals

Decided May 15, 1928No. Docket No. 11306Published

1. Under a deed executed in 1907, the petitioner was granted a one-half undivided remainder interest in certain real estate in Anderson, S.C., upon the condition that he survive the life tenant. If he alone should survive the life tenant then he was to take all of the remainder. In 1920 the petitioner and the coremainderman bought out the life tenant.

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1. Under a deed executed in 1907, the petitioner was granted a one-half undivided remainder interest in certain real estate in Anderson, S.C., upon the condition that he survive the life tenant. If he alone should survive the life tenant then he was to take all of the remainder. In 1920 the petitioner and the coremainderman bought out the life tenant. Held, that the interest in the real estate acquired by the petitioner under the deed was property within the meaning of the taxing statute and capable of definite valuation on the basic date. 2. Fair market value of petitioner's interest at…

1Opinion of the Court

J. S. F. CRAYTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Crayton v. Commissioner

Docket No. 11306.

United States Board of Tax Appeals

11 B.T.A. 1375; 1928 BTA LEXIS 3627;

May 15, 1928, Promulgated

1. Under a deed executed in 1907, the petitioner was granted a one-half undivided remainder interest in certain real estate in Anderson, S.C., upon the condition that he survive the life tenant. If he alone should survive the life tenant then he was to take all of the remainder. In 1920 the petitioner and the coremainderman bought out the life tenant. Held, that the interest in the…

2Cases cited11 opinions

  1. Knight v. United States Land Assn.Supreme Court of the United States · 1891
  2. Lynch v. Alworth-Stephens Co.Supreme Court of the United States · 1925
  3. Delassus v. United StatesSupreme Court of the United States · 1835
  4. Charleston & Western Car. Ry. Co. v. ReynoldsSupreme Court of South Carolina · 1904
  5. Earle v. MaxwellSupreme Court of South Carolina · 1910

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