Legal Opinion
Commissioner of Internal Revenue v. Pearson
Court of Appeals for the Fifth Circuit
Decided May 24, 1951No. 13387PublishedCited by 20 opinions
1Opinion of the Court
HUTCHESON, Chief Judge.
This is one of three cases 1 in which, though the lessor ancestor, having no cost, had no basis for depreciation, 2 the Tax Court has held that, under Sec. 113(a) (5), I.R.C., 26 U.S.C.A. § 113(a) (5) 3 an heir has such a base in a building constructed by the lessee.
Taxpayer here, Helen Blesi Pearson, inherited an interest in the Gulf States Building property, a lot in downtown Dallas which was subject to a long term lease and on which the lessee had constructed a building at its sole expense, the building having an estimated useful life less than the term of the lease.
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2Cases cited8 opinions
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Moore v. CommissionerUnited States Tax Court · 1950
- Friend v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1941
- Reisinger v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1944
- Pearson v. CommissionerUnited States Tax Court · 1949
3 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Commissioner of Internal Revenue v. Moore. Moore v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
- Rowan v. CommissionerUnited States Tax Court · 1954
- Schubert v. CommissionerUnited States Tax Court · 1960
- Rosalie M. Schubert v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1961
- World Publishing Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1962
15 more not listed; retrieve them via the Exa API.