Legal Opinion

Bryant Trust v. Commissioner

United States Tax Court

Decided September 27, 1948No. Docket No. 14508Published

The taxpayer trust acquired by devise in 1920 land and building subject to lease until 1967 under a contract which permitted the lessee, who had constructed the building at his own expense, to recover its cost, plus interest, by retention of the rentals due under the lease.

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The taxpayer trust acquired by devise in 1920 land and building subject to lease until 1967 under a contract which permitted the lessee, who had constructed the building at his own expense, to recover its cost, plus interest, by retention of the rentals due under the lease. The trust paid off the unreimbursed cost in 1932 and sold the property in 1941. (1) The value of the "property" at the time of acquisition by devise, which value was the trust's basis, held, to be the value of the leased land and building without diminution on account of contract provisions permitting the lessee's…

1Opinion of the Court

Harriet M. Bryant Trust, Dr. Carl Bryant Schutz, et al., Trustees, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bryant Trust v. Commissioner

Docket No. 14508

United States Tax Court

11 T.C. 374; 1948 U.S. Tax Ct. LEXIS 79;

September 27, 1948, Promulgated

Decision will be entered under Rule 50.

The taxpayer trust acquired by devise in 1920 land and building subject to lease until 1967 under a contract which permitted the lessee, who had constructed the building at his own expense, to recover its cost, plus interest, by retention of the rentals due under the lease. The trust paid off…

2Cases cited4 opinions

  1. Crane v. CommissionerSupreme Court of the United States · 1947
  2. Crooks v. HarrelsonSupreme Court of the United States · 1930
  3. Cleveland, Cincinnati, Chicago & St. Louis Railway Co. v. BackusSupreme Court of the United States · 1894
  4. Bryant Trust v. CommissionerUnited States Tax Court · 1948

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