Legal Opinion

Kissel v. Commissioner

United States Board of Tax Appeals

Decided March 5, 1929No. Docket No. 18203Published

Where one owning a life interest in a piece of real property erects with her own funds a building thereon, the life of which extends far beyond the life expectancy of the life tenant, held, that she is entitled to deduct each year that portion of the cost which the taxable year bears to her total expectancy of life, as shown by the life tables.

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Where one owning a life interest in a piece of real property erects with her own funds a building thereon, the life of which extends far beyond the life expectancy of the life tenant, held, that she is entitled to deduct each year that portion of the cost which the taxable year bears to her total expectancy of life, as shown by the life tables. Held, further, that she is not entitled under these circumstances to an additional deduction representing exhaustion of the building over its own life.

1Opinion of the Court

CAROLINE T. KISSEL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Kissel v. Commissioner

Docket No. 18203.

United States Board of Tax Appeals

15 B.T.A. 705; 1929 BTA LEXIS 2805;

March 5, 1929, Promulgated

Where one owning a life interest in a piece of real property erects with her own funds a building thereon, the life of which extends far beyond the life expectancy of the life tenant, held, that she is entitled to deduct each year that portion of the cost which the taxable year bears to her total expectancy of life, as shown by the life tables. Held, further, that she is not…

2Cases cited1 opinion

  1. Kissel v. CommissionerUnited States Board of Tax Appeals · 1929

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