Legal Opinion

Lone Pine Lawn Corp. v. Commissioner

United States Board of Tax Appeals

Decided March 21, 1940No. Docket No. 94298PublishedCited by 11 opinions

Petitioner, a personal holding company, having acquired for its capital stock a remainder over after intervening life estates in Connecticut real estate, held, not to be entitled to deductions for real property taxes and fire insurance premiums paid by it on the property pursuant to its agreement with the life tenant grantor; held further, deduction for depreciation thereon disallowed to petitioner. Revenue Act of 1934, sec. 23(1).

1Opinion of the Court

*640OPINION.

OppeR:

Petitioner, a personal holding company, claims to be entitled to deductions for taxes, fire insurance, and depreciation on *641real property acquired by it in exchange for a part of its capital stock. A further question is the liability for a delinquency penalty resulting from petitioner’s failure to file a personal holding company return within the time prescribed.

The primary issues would be simple of solution were it not for the fact that petitioner’s interest in the real property in question is limited to a remainder over after one, or possibly two, intervening life estates.…

2Cases cited1 opinion

  1. United States v. Railroad Co.Supreme Court of the United States · 1873

3Cited by11 opinions

  1. Reffett v. CommissionerUnited States Tax Court · 1963
  2. 1040 Springfield Ave. Corp. v. CommissionerUnited States Tax Court · 1949
  3. Burton Swartz Land Corp. v. CommissionerUnited States Tax Court · 1951
  4. Lane-Wells Co. v. CommissionerUnited States Board of Tax Appeals · 1941
  5. Lone Pine Lawn Corp. v. CommissionerUnited States Board of Tax Appeals · 1940

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