A. Glendon Johnson, Administrator C.T.A. Estate of A. Gales Johnson v. Commissioner of Internal Revenue

THOMSEN, District Judge.

This case arises out of the fiduciary income tax returns of the estate of A. Gales Johnson for the fiscal years ended August 31, 1951 and 1952. The principal issues are: (1) the basis upon which depreciation and obsolescence should be allowed on certain assets which had been included in the estate tax return, and (2) whether certain assets on which taxpayer claimed an allowance for obsolescence were in fact obsolete.

Decedent had been the sole proprietor of a mail-order business selling original house designs prepared by decedent and his staff. Induced by…