Currier v. Commissioner
United States Tax Court
Held, taxpayer did not have a depreciable interest in certain real property: Charles Bertram Currier, 7 T.C. 980 (1946), is not res judicata as to this proceeding, involving different taxable years, nor does it act as a collateral estoppel as to matters in this proceeding which were not actually presented and determined in the earlier suit. Commissioner v. Sunnen, 333 U.S. 591 (1948).
1Opinion of the Court
Catharine B. Currier and C. Bertram Currier, Petitioners v. Commissioner of Internal Revenue, Respondent
Currier v. Commissioner
Docket No. 2586-66
United States Tax Court
51 T.C. 488; 1968 U.S. Tax Ct. LEXIS 5;
December 26, 1968, Filed
Decision will be entered for the Commissioner.
Held, taxpayer did not have a depreciable interest in certain real property: Charles Bertram Currier, 7 T.C. 980 (1946), is not res judicata as to this proceeding, involving different taxable years, nor does it act as a collateral estoppel as to matters in this proceeding which were not actually presented and determined…
2Cases cited17 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Rowan v. CommissionerUnited States Tax Court · 1954
- Commissioner of Internal Revenue v. Revere Land Co.Court of Appeals for the Third Circuit · 1948
12 more not listed; retrieve them via the Exa API.