Stern v. Commissioner
United States Board of Tax Appeals
1. Petitioners seek deductions of proportionate parts of losses sustained upon two pieces of property in the taxable year, claiming absolute ownership, a vested legal and equitable title to their respective shares in the properties under the wills of their father and mother. The properties originally were owned jointly or in common by petitioners' father and maternal grandfather, who by will devised their respective interests in trust.
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1. Petitioners seek deductions of proportionate parts of losses sustained upon two pieces of property in the taxable year, claiming absolute ownership, a vested legal and equitable title to their respective shares in the properties under the wills of their father and mother. The properties originally were owned jointly or in common by petitioners' father and maternal grandfather, who by will devised their respective interests in trust. Petitioners' mother likewise by will devised her interest in the properties under her father's will, in trust. Held, the evidence fails to establish that the…
1Opinion of the Court
CORA S. STERN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
PHILIP L. SEASONGOOD, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Stern v. Commissioner
Docket Nos. 16692, 18862.
United States Board of Tax Appeals
14 B.T.A. 444; 1928 BTA LEXIS 2973;
November 27, 1928, Promulgated
1. Petitioners seek deductions of proportionate parts of losses sustained upon two pieces of property in the taxable year, claiming absolute ownership, a vested legal and equitable title to their respective shares in the properties under the wills of their father and mother. The properties…
2Cases cited1 opinion
- Stern v. CommissionerUnited States Board of Tax Appeals · 1928