Audigier v. Commissioner
United States Tax Court
Previous to their marriage, petitioner's late husband conveyed certain business property to the University of Tennessee, reserving to himself a life interest, together with the right to "* * * make * * * leases thereon for any term * * *." After the marriage, the university acceded to the husband's request to pay over to petitioner for life, in case she survived him, one-half of the net income from the property.
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Previous to their marriage, petitioner's late husband conveyed certain business property to the University of Tennessee, reserving to himself a life interest, together with the right to "* * * make * * * leases thereon for any term * * *." After the marriage, the university acceded to the husband's request to pay over to petitioner for life, in case she survived him, one-half of the net income from the property. Later petitioner, her husband, and the university, as lessors, and a Tennessee corporation, as lessee, executed a 99-year lease of the property, in which, inter alia, the university…
1Opinion of the Court
Carro May Audigier, Petitioner, v. Commissioner of Internal Revenue, Respondent
Audigier v. Commissioner
Docket No. 40402
United States Tax Court
21 T.C. 665; 1954 U.S. Tax Ct. LEXIS 298;
February 8, 1954, Promulgated
Decision will be entered under Rule 50.
Previous to their marriage, petitioner's late husband conveyed certain business property to the University of Tennessee, reserving to himself a life interest, together with the right to "* * * make * * * leases thereon for any term * * *." After the marriage, the university acceded to the husband's request to pay over to petitioner for life, in…
Also in this document: Dissent.
2Cases cited31 opinions
- Bogardus v. CommissionerSupreme Court of the United States · 1937
- Irwin v. GavitSupreme Court of the United States · 1925
- Fire Ins. Assn., Ltd. v. WickhamSupreme Court of the United States · 1891
- Carragan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Weil v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1936
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