Herbert v. Commissioner
United States Tax Court
Petitioner during the taxable years was a British subject residing in England. When she was quite young her father gave to her and her sister a piece of real property located in Washington, D. C. Since 1940 this property (the only real property owned by petitioner in the United States) has been rented to one tenant, who is responsible for its operation and for repairs except as to foundation and outer walls.
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Petitioner during the taxable years was a British subject residing in England. When she was quite young her father gave to her and her sister a piece of real property located in Washington, D. C. Since 1940 this property (the only real property owned by petitioner in the United States) has been rented to one tenant, who is responsible for its operation and for repairs except as to foundation and outer walls. During the taxable years (1952 and 1953) petitioner's sole activities in connection with this property, other than the receipt of rentals, consisted of payments of taxes, insurance, and…
1Opinion of the Court
Elizabeth Herbert, Petitioner, v. Commissioner of Internal Revenue, Respondent
Herbert v. Commissioner
Docket No. 61138
United States Tax Court
30 T.C. 26; 1958 U.S. Tax Ct. LEXIS 214;
April 15, 1958, Filed
Decision will be entered under Rule 50.
Petitioner during the taxable years was a British subject residing in England. When she was quite young her father gave to her and her sister a piece of real property located in Washington, D. C. Since 1940 this property (the only real property owned by petitioner in the United States) has been rented to one tenant, who is responsible for its operation and…
2Cases cited4 opinions
- Fackler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1943
- Lewenhaupt v. CommissionerUnited States Tax Court · 1953
- Grier v. United StatesDistrict Court, D. Connecticut · 1954
- Herbert v. CommissionerUnited States Tax Court · 1958