Perkins v. Commissioner
United States Board of Tax Appeals
1. Where nonbusiness property is acquired by gift, held basis for depreciation is value at date of conversion to business use by donee. 2. Surrender for cash to issuing company of insurance policy acquired by gift, held to require computation of gain as ordinary income. George A. Hellman,33 B.T.A. 901, followed. 3. Various other questions determined relating to losses and bad debts claimed by petitioners.
1Opinion of the Court
OPINION.
Oppee :
These proceedings, consolidated for hearing and consideration, were brought for a redetermination of deficiencies in income tax as follows:
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A question relating to certain accounting and bookkeeping expenses for the years 1935 and 1936 in Docket No. 96126 being apparently conceded by petitioner, the questions remaining for decision are as follows:
I. Whether the proper basis for computing depreciation of property acquired by gift is cost to the donor, or fair market value on the date of gift.
II. Whether insurance policies surrendered for cash, in accordance with a…
2Cases cited4 opinions
- White v. United StatesSupreme Court of the United States · 1938
- Heiner v. TindleSupreme Court of the United States · 1928
- Fairbanks v. United StatesSupreme Court of the United States · 1939
- Helvering v. Chester N. Weaver Co.Supreme Court of the United States · 1938
3Cited by13 opinions
- Au v. CommissionerUnited States Tax Court · 1963
- J. Russell Parsons and Margaret C. Parsons v. United StatesCourt of Appeals for the Third Circuit · 1955
- Lowndes v. United StatesDistrict Court, D. Maryland · 1966
- Westerhaus Co. v. CommissionerUnited States Tax Court · 1957
- Au v. CommissionerUnited States Tax Court · 1963
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