Meredith v. Commissioner
United States Tax Court
Petitioner abandoned resort property as a secondary residence and immediately offered it for sale and/or rent. She retained the property for approximately 21 years receiving no rental income therefrom.
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Petitioner abandoned resort property as a secondary residence and immediately offered it for sale and/or rent. She retained the property for approximately 21 years receiving no rental income therefrom. Held, by the time of the years in issue petitioner could not have had a reasonable expectation of receiving any rental income and she never held the property for appreciation in value; hence, the property was not "property held for the production of income" within the meaning of secs. 167 and 212, I.R.C. 1954. Held, further, respondent's determination that petitioner failed to include a…
1Opinion of the Court
Ida Meredith, Petitioner v. Commissioner of Internal Revenue, Respondent
Meredith v. Commissioner
Docket Nos. 6897-73, 6898-73
United States Tax Court
65 T.C. 34; 1975 U.S. Tax Ct. LEXIS 55;
October 14, 1975, Filed
Decisions will be entered for the respondent.
Petitioner abandoned resort property as a secondary residence and immediately offered it for sale and/or rent. She retained the property for approximately 21 years receiving no rental income therefrom. Held, by the time of the years in issue petitioner could not have had a reasonable expectation of receiving any rental income and she never…
2Cases cited20 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- United States v. GilmoreSupreme Court of the United States · 1963
- Coors v. CommissionerUnited States Tax Court · 1973
- Adolph Coors Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1975
- Leslie v. CommissionerUnited States Tax Court · 1946
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