May v. Commissioner
United States Tax Court
T entered into an arrangement in which he purported to purchase 13 television film episodes for an alleged purchase price of $365,000. His out-of-pocket costs were $35,000 and it was never intended that he pay any more, notwithstanding that he was theoretically obligated to pay the entire purchase price. He attempted to take depreciation deductions aggregating $365,000 over a two-year period.
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T entered into an arrangement in which he purported to purchase 13 television film episodes for an alleged purchase price of $365,000. His out-of-pocket costs were $35,000 and it was never intended that he pay any more, notwithstanding that he was theoretically obligated to pay the entire purchase price. He attempted to take depreciation deductions aggregating $365,000 over a two-year period. Held, in the circumstances of this case, this was not a bona fide purchase, and T was not entitled to the claimed deductions.
1Opinion of the Court
Marvin M. May and Lorraine May v. Commissioner.
May v. Commissioner
Docket Nos. 2255-66, 2256-66, 2257-66, 1718-67.
United States Tax Court
T.C. Memo 1972-70; 1972 Tax Ct. Memo LEXIS 186; 31 T.C.M. (CCH) 279; T.C.M. (RIA) 72070;
March 22, 1972, Filed
T entered into an arrangement in which he purported to purchase 13 television film episodes for an alleged purchase price of $365,000. His out-of-pocket costs were $35,000 and it was never intended that he pay any more, notwithstanding that he was theoretically obligated to pay the entire purchase price. He attempted to take depreciation deductions…
2Cases cited9 opinions
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Furman v. CommissionerUnited States Tax Court · 1966
- Irvine K. Furman and Lorena K. Furman v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
- W. H. Armston Co., Inc. v. Commissioner of Internal Revenue. Armston v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Commissioner of Internal Revenue v. Moore. Moore v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
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