Crayton v. Commissioner
United States Board of Tax Appeals
1. Under a deed executed in 1907, the petitioner was granted a one-half undivided remainder interest in certain real estate in Anderson, S.C., upon the condition that he survive the life tenant. If he alone should survive the life tenant then he was to take all of the remainder. In 1920 the petitioner and the coremainderman bought out the life tenant.
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1. Under a deed executed in 1907, the petitioner was granted a one-half undivided remainder interest in certain real estate in Anderson, S.C., upon the condition that he survive the life tenant. If he alone should survive the life tenant then he was to take all of the remainder. In 1920 the petitioner and the coremainderman bought out the life tenant. Held, that the interest in the real estate acquired by the petitioner under the deed was property within the meaning of the taxing statute and capable of definite valuation on the basic date. 2. Fair market value of petitioner's interest at…
1Opinion of the Court
*1379OPINION.
Smith:
The petitioner and the respondent are substantially in accord as to the amount of petitioner’s gross receipts from- the sale of the property in 1920 hut are at difference both as to the date of its acquisition by petitioner and as to its cost or March 1,1913, value. The petitioner contends that he did not acquire the property prior to March, 1920; that under the Hortense C. Fowler deed executed in 1907 he acquired only a contingent interest in the property which did not vest or become a certainty until by virtue of the agreement entered into in 1920. In support of this…
2Cases cited7 opinions
- Knight v. United States Land Assn.Supreme Court of the United States · 1891
- Lynch v. Alworth-Stephens Co.Supreme Court of the United States · 1925
- Delassus v. United StatesSupreme Court of the United States · 1835
- Charleston & Western Car. Ry. Co. v. ReynoldsSupreme Court of South Carolina · 1904
- Earle v. MaxwellSupreme Court of South Carolina · 1910
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3Cited by1 opinion
- Crayton v. CommissionerUnited States Board of Tax Appeals · 1928