Legal Opinion

Shea v. Commissioner

United States Board of Tax Appeals

Decided November 1, 1934No. Docket No. 61544PublishedCited by 9 opinions

This Board has no jurisdiction of a proceeding brought by a life tenant in her individual capacity, for the redetermination of a deficiency based on a notice sent to her as trustee for remaindermen.

1Opinion of the Court

OPINION.

Mttkdock :

The Commissioner sent a notice of deficiency addressed to “ Mrs. Mary M. Shea, Trustee, Isabell Shea, et al ”, advising that he had determined a deficiency of $6,436.40 for 1929 and a penalty of $1,609.10 for delinquency in failing to file a return. A piece of property in Louisville, Kentucky, had been taken by the Federal Government by condemnation. The owners had been awarded $75,000 for the'property taken. The Commissioner used $16,000 as the fair market value of the property on March 1, 1913. He deducted $2,560 on account of depreciation, added $2,000 as expenses of the…

2Cited by9 opinions

  1. Estate of Eversole v. CommissionerUnited States Tax Court · 1963
  2. United States v. De BonchampsCourt of Appeals for the Ninth Circuit · 1960
  3. Du Puy v. CommissionerUnited States Tax Court · 1967
  4. Cooke v. United StatesDistrict Court, D. Hawaii · 1953
  5. Crews v. CommissionerUnited States Tax Court · 1988

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