Legal Opinion

Gifford v. Commissioner

United States Board of Tax Appeals

Decided January 16, 1926No. Docket Nos. 2677 and 2678Published

1. In the case of a tenant holding and using premises under a lease from year to year where the landlord is a member of the tenant partnership, the cost of improvements and additions to buildings on leased premises and of removable machinery and equipment, charged to expense when made or acquired, may be restored to the tenant's asset accounts for the purposes of invested capital, upon proof of the continued existence and use of such properties during the taxable year. 2. A…

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1. In the case of a tenant holding and using premises under a lease from year to year where the landlord is a member of the tenant partnership, the cost of improvements and additions to buildings on leased premises and of removable machinery and equipment, charged to expense when made or acquired, may be restored to the tenant's asset accounts for the purposes of invested capital, upon proof of the continued existence and use of such properties during the taxable year. 2. A deduction for a loss of the par value of stock of a bankrupt corporation can not be allowed in the absence of proof of…

1Opinion of the Court

APPEALS OF HARRY N. GIFFORD AND LOUIS W. CULLUM.

Gifford v. Commissioner

Docket Nos. 2677 and 2678.

United States Board of Tax Appeals

3 B.T.A. 334; 1926 BTA LEXIS 2686;

January 16, 1926, Decided Submitted June 1, 1925.

1. In the case of a tenant holding and using premises under a lease from year to year where the landlord is a member of the tenant partnership, the cost of improvements and additions to buildings on leased premises and of removable machinery and equipment, charged to expense when made or acquired, may be restored to the tenant's asset accounts for the purposes of invested capital,…

2Cases cited1 opinion

  1. Appeals of GiffordUnited States Board of Tax Appeals · 1926

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