Legal Opinion

Davies v. Commissioner

United States Tax Court

Decided February 5, 1970No. Docket No. 1686-69SCPublished

Petitioner and her sister conveyed an apartment building to an Illinois land trust, for the benefit of themselves, two other sisters, and a brother. Petitioner lived in one apartment, paying rent. The building was sold, the trust terminated, and petitioner bought a house with her share of the proceeds.

Read the full summary

Petitioner and her sister conveyed an apartment building to an Illinois land trust, for the benefit of themselves, two other sisters, and a brother. Petitioner lived in one apartment, paying rent. The building was sold, the trust terminated, and petitioner bought a house with her share of the proceeds. Held, petitioner is not entitled to nonrecognition of any part of her gain under sec. 1034, I.R.C. 1954. Held, further, uncollected loans made by petitioner to the land trust were not bad debts.

1Opinion of the Court

Blanche F. Davies, Petitioner v. Commissioner of Internal Revenue, Respondent

Davies v. Commissioner

Docket No. 1686-69SC

United States Tax Court

54 T.C. 170; 1970 U.S. Tax Ct. LEXIS 223;

February 5, 1970, Filed

Decision will be entered for the respondent.

Petitioner and her sister conveyed an apartment building to an Illinois land trust, for the benefit of themselves, two other sisters, and a brother. Petitioner lived in one apartment, paying rent. The building was sold, the trust terminated, and petitioner bought a house with her share of the proceeds. Held, petitioner is not entitled to…

2Cases cited3 opinions

  1. American Felt Co. v. BurnetCourt of Appeals for the D.C. Circuit · 1932
  2. Davies v. CommissionerUnited States Tax Court · 1970
  3. Brubaker v. CommissionerUnited States Tax Court · 1957

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API