Bolger v. Commissioner
United States Tax Court
Corporations were organized to acquire title to properties, issue promissory notes secured by mortgages, and execute leases in order to provide maximum financing by avoiding State law restrictions on loans to individuals, to provide a mechanism for limiting the personal liability of such individuals, and to facilitate multiple-lender financing.
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Corporations were organized to acquire title to properties, issue promissory notes secured by mortgages, and execute leases in order to provide maximum financing by avoiding State law restrictions on loans to individuals, to provide a mechanism for limiting the personal liability of such individuals, and to facilitate multiple-lender financing. Upon the consummation of the foregoing transactions, the corporations immediately transferred the properties to the individuals, subject to the mortgages and leases but without such individuals assuming any personal liability. Each corporation was…
1Opinion of the Court
Tannenwald, Judge:
Despondent determined the following deficiencies in petitioners’ income tax:
Year Deficiency
1963 _$13,153.44
1964 _ 22,696.75
1965 _ 30,512.00
1966 _ 90,186.00
Certain concessions Raving been made, tbe only issue remaining for our consideration is whether petitioners are entitled to deductions for depreciation on account of certain real and personal property under the circumstances set forth herein. A decision with respect to this issue governs the allowability of rental and. interest expenses and the investment credits claimed by petitioners.
EINDINGS OE EACT
Some of the facts…
2Cases cited29 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Crane v. CommissionerSupreme Court of the United States · 1947
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
24 more not listed; retrieve them via the Exa API.
3Cited by87 opinions
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Estate of Franklin v. CommissionerUnited States Tax Court · 1975
- Hilton v. CommissionerUnited States Tax Court · 1980
- Strong v. CommissionerUnited States Tax Court · 1976
- Brountas v. CommissionerUnited States Tax Court · 1979
82 more not listed; retrieve them via the Exa API.