Ziegler v. Commissioner
United States Board of Tax Appeals
A payment made by a taxpayer to secure to himself the management of a trust estate, of which he was sole beneficiary, during the balance of the life of the trust is not deductible as an expense in the year of its payment but should be written off and deducted ratably over the period of the control so secured. The par value of the entire stock of a corporation issued in exchange for property is not evidence of the value of the stock nor of the value of the property.
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A payment made by a taxpayer to secure to himself the management of a trust estate, of which he was sole beneficiary, during the balance of the life of the trust is not deductible as an expense in the year of its payment but should be written off and deducted ratably over the period of the control so secured. The par value of the entire stock of a corporation issued in exchange for property is not evidence of the value of the stock nor of the value of the property. In the absence of any evidence, real property consisting of land and buildings can not be presumed to have appreciated to an…
1Opinion of the Court
*189OPINION.
Ivins :
The first question before the Board arises out of the dis-allowance by the Commissioner of a deduction of $200,000 claimed by the taxpayer in his 1919 return, that amount representing a sum paid by him to two trustees of a trust, under which he was the sole beneficiary, in consideration of their resignations as such trustees.
The taxpayer was the sole beneficiary of a trust created by the will of his father, the terms of which provided that he shouid receive *190the income (after his majority) and that the principal should be turned over to him in four equal installments as he…
2Cited by12 opinions
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- Burge v. CommissionerUnited States Board of Tax Appeals · 1926
- Dohrmann v. CommissionerUnited States Board of Tax Appeals · 1930
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