Louis v. Commissioner
United States Board of Tax Appeals
Petitioner acquired an annuity in consideration of a surrender of a part of her interest in her father's estate. Such annuity was terminated in the taxable year by the death of her mother, upon whose life expectancy it was based. Held, that the unrecovered cost of the annuity at date of termination was a loss in the year the contract was terminated.
1Opinion of the Court
OPINION.
Lansdon:
The respondent has determined a deficiency in income tax for the year 1925 in the amount of $1,107.09, from which the petitioner appeals on the allegation that a loss sustained in that year has been erroneously disallowed as a deduction from gross income. *1201Tlie parties have filed a stipulation, -which is accepted and incorporated herein by reference. The following is a summary of the material facts:
Petitioner is an individual who resides at Los Angeles, California. Her father died testate on December 28, 1912, and in his will, probated in Cook County, Illinois, on January 2,…
2Cases cited4 opinions
- Helvering v. ButterworthSupreme Court of the United States · 1933
- Guaranty Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Pioneer Cooperage Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Curtis v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by1 opinion
- Louis v. CommissionerUnited States Board of Tax Appeals · 1934