Butler v. Commissioner
United States Tax Court
On Apr. 30, 1963, petitioner Frank L. Butler transferred his medical office building to a bank, as trustee, for his minor children for a period of 11 years, and contemporaneously leased it back for the same period. At the termination of the trust, the building will pass to his wife, petitioner Cecelia F. Butler. Held, petitioners are not entitled to deductions under sec. 162(a)(3), I.R.C. 1954, for the rent paid to the trust during 1970 and 1971.
1Opinion of the Court
OPINION
Featherston, Judge:
Respondent determined the following deficiencies in petitioners’ income tax:
Year Amount
1970_ $1,450.81
1971__ 1,331.03
The only issue for decision is whether petitioners are entitled to deductions under section 162(a)(3)1 for rental payments made during 1970 and 1971 in respect of an office building which petitioner Frank L. Butler transferred to, and leased back from, a trust.
The facts are all stipulated.
Petitioners Frank L. Butler and Cecelia F. Butler were legal residents of McComb, Miss., at the time they filed their petition. They filed joint Federal income tax…
2Cases cited15 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- 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
- Skemp v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1948
- I. L. Van Zandt and Ruth B. Van Zandt v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
10 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Lerner v. CommissionerUnited States Tax Court · 1978
- Butler v. CommissionerUnited States Tax Court · 1975
- Carroll v. CommissionerUnited States Tax Court · 1978
- Lerner v. CommissionerUnited States Tax Court · 1978
- May v. CommissionerUnited States Tax Court · 1981
2 more not listed; retrieve them via the Exa API.