Johnson v. Commissioner
United States Tax Court
1. Petitioners in 1940 abandoned their residence (Plot "A") and offered the same for sale or rent. The main house was never rented, but the petitioners received rental income from certain minor portions of the premises from the time of abandonment until its sale in 1945. Held, petitioners sustained no deductible loss within the purview of section 23 (e), I. R. C., on the sale of such former residence in the taxable year 1945. 2. Petitioner, E. R. Fenimore Johnson,…
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1. Petitioners in 1940 abandoned their residence (Plot "A") and offered the same for sale or rent. The main house was never rented, but the petitioners received rental income from certain minor portions of the premises from the time of abandonment until its sale in 1945. Held, petitioners sustained no deductible loss within the purview of section 23 (e), I. R. C., on the sale of such former residence in the taxable year 1945. 2. Petitioner, E. R. Fenimore Johnson, individually owned unimproved real estate (Plot "B") adjoining Plot "A" and which he sold as a unit with Plot "A" in 1945. Held,…
1Opinion of the Court
E. R. Fenimore Johnson, Petitioner, v. Commissioner of Internal Revenue, Respondent. Janet Darby Johnson, Petitioner, v. Commissioner of Internal Revenue, Respondent
Johnson v. Commissioner
Docket Nos. 23114, 23115
United States Tax Court
19 T.C. 93; 1952 U.S. Tax Ct. LEXIS 63;
October 28, 1952, Promulgated
Decisions will be entered under Rule 50.
1. Petitioners in 1940 abandoned their residence (Plot "A") and offered the same for sale or rent. The main house was never rented, but the petitioners received rental income from certain minor portions of the premises from the time of abandonment until…
2Cases cited7 opinions
- Heiner v. TindleSupreme Court of the United States · 1928
- Robinson v. CommissionerUnited States Tax Court · 1943
- Horrmann v. CommissionerUnited States Tax Court · 1951
- Schmidlapp v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1938
- Rumsey v. CommissionerCourt of Appeals for the Second Circuit · 1936
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