Legal Opinion

Hendrick v. Commissioner

United States Tax Court

Decided March 31, 1961No. Docket No. 81690PublishedCited by 38 opinions

1. Commissioner's determination of basis for depreciation of portion of personal residence converted to rental property sustained where petitioner failed to establish fair market value of building at date of partial conversion or that amount spent in conversion was not for work on the portion retained as a personal residence as well as portion converted to rental property. 2. Attorneys fees paid to obtain admission to probate of copy of will, the original of which could not…

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1. Commissioner's determination of basis for depreciation of portion of personal residence converted to rental property sustained where petitioner failed to establish fair market value of building at date of partial conversion or that amount spent in conversion was not for work on the portion retained as a personal residence as well as portion converted to rental property. 2. Attorneys fees paid to obtain admission to probate of copy of will, the original of which could not be located, are not deductible as expenses for the production of income or the management, conservation, or maintenance…

1Opinion of the Court

Scott, Judge:

Respondent determined deficiencies in the income tax of petitioners for the years 1954, 1955, 1956, and 1957 in the amounts of $1,433.71, $941.67, $394.29, and $3,557.05, respectively.

The issues for decision are:(1) The amounts of deductions for depreciation to which petitioners are entitled for the years 1954, 1955, 1956, and 1957 with respect to certain rental property owned by them;(2) Whether petitioners are entitled to a deduction for legal fees paid by them in the taxable year 1954;(3) Whether petitioners are entitled to a deduction for an appraisal fee paid by them in the…

2Cases cited8 opinions

  1. Bowers v. LumpkinCourt of Appeals for the Fourth Circuit · 1944
  2. Daniel S. W. Kelly v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
  3. Kelly v. CommissionerUnited States Tax Court · 1955
  4. Coughlin v. CommissionerUnited States Tax Court · 1944
  5. Rowe v. CommissionerUnited States Tax Court · 1955

3 more not listed; retrieve them via the Exa API.

3Cited by38 opinions

  1. Fischer v. CommissionerUnited States Tax Court · 1968
  2. Atkinson v. CommissionerUnited States Tax Court · 1965
  3. Wilson v. Comm'rUnited States Tax Court · 1961
  4. Lichterman v. CommissionerUnited States Tax Court · 1961
  5. Grunwald v. CommissionerUnited States Tax Court · 1968

33 more not listed; retrieve them via the Exa API.

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