Penn v. Commissioner
United States Tax Court
Petitioner, life tenant of real estate bearing a building largely unproductive, razed it and erected at her own expense an income-producing building. At the time she had a life expectancy of 7 years but the property had a useful life of 50 years. Held, the Commissioner did not err in allowing depreciation deduction on a basis of estimated useful life of the building and disallowing it on basis of petitioner's life expectancy.
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Petitioner, life tenant of real estate bearing a building largely unproductive, razed it and erected at her own expense an income-producing building. At the time she had a life expectancy of 7 years but the property had a useful life of 50 years. Held, the Commissioner did not err in allowing depreciation deduction on a basis of estimated useful life of the building and disallowing it on basis of petitioner's life expectancy. Caroline T. Kissell, 15 B. T. A. 705, distinguished.
1Opinion of the Court
Margaret Penn, Petitioner, v. Commissioner of Internal Revenue, Respondent
Penn v. Commissioner
Docket No. 26623
United States Tax Court
16 T.C. 1497; 1951 U.S. Tax Ct. LEXIS 145;
June 29, 1951, Promulgated
Decision will be entered for the respondent.
Petitioner, life tenant of real estate bearing a building largely unproductive, razed it and erected at her own expense an income-producing building. At the time she had a life expectancy of 7 years but the property had a useful life of 50 years. Held, the Commissioner did not err in allowing depreciation deduction on a basis of estimated useful life…
2Cases cited3 opinions
- Wolff v. CommissionerUnited States Tax Court · 1946
- Grant v. RoseDistrict Court, N.D. Georgia · 1929
- Penn v. CommissionerUnited States Tax Court · 1951