Legal Opinion

Smith v. Commissioner

United States Tax Court

Decided February 15, 1967No. Docket No. 6628-65UnpublishedCited by 2 opinions

For approximately 20 years prior to December 1961, petitioners lived in a large house in Arcadia, California, which was near Los Angeles. During December 1961 petitioners permanently abandoned the house in Arcadia as a residence and moved to Pebble Beach, California, a distance of some 400 miles.

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For approximately 20 years prior to December 1961, petitioners lived in a large house in Arcadia, California, which was near Los Angeles. During December 1961 petitioners permanently abandoned the house in Arcadia as a residence and moved to Pebble Beach, California, a distance of some 400 miles. They immediately offered the Arcadia property for sale and sold it in 1964. During 1962 and 1963 petitioners expended the sums of $2,744.21 and $2,640.40, respectively, for maintenance and repair of the Arcadia property. The improvements on the Arcadia property had a cost basis of $60,940, as of…

1Opinion of the Court

Hulet P. Smith and Loma M. Smith v. Commissioner.

Smith v. Commissioner

Docket No. 6628-65.

United States Tax Court

T.C. Memo 1967-28; 1967 Tax Ct. Memo LEXIS 234; 26 T.C.M. (CCH) 149; T.C.M. (RIA) 67028;

February 15, 1967

For approximately 20 years prior to December 1961, petitioners lived in a large house in Arcadia, California, which was near Los Angeles. During December 1961 petitioners permanently abandoned the house in Arcadia as a residence and moved to Pebble Beach, California, a distance of some 400 miles. They immediately offered the Arcadia property for sale and sold it in 1964. During…

2Cases cited3 opinions

  1. Robinson v. CommissionerUnited States Tax Court · 1943
  2. Mitchell v. CommissionerUnited States Tax Court · 1966
  3. Briley v. United StatesDistrict Court, N.D. Ohio · 1960

3Cited by2 opinions

  1. Lowry v. United StatesDistrict Court, D. New Hampshire · 1974
  2. Scott v. CommissionerUnited States Tax Court · 1968

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