Legal Opinion

Harman v. Commissioner

United States Tax Court

Decided November 24, 1944No. Docket Nos. 1145, 1146Published

1. Petitioners were devised undivided life interests in coal lands in West Virginia, under the law of which they became vested with legal title. The lands were, under the facts, not subject to payment of the testator's debts.

Read the full summary

1. Petitioners were devised undivided life interests in coal lands in West Virginia, under the law of which they became vested with legal title. The lands were, under the facts, not subject to payment of the testator's debts. Held, that loss sustained upon sale and execution of deed by the petitioners of their life interests was that of the petitioners, and not of the testator's estate, and was a capital loss. 2. Petitioner paid an attorney a lump sum for legal advice in connection with a condemnation proceeding and for procuring a loan. Held, that the expense of legal advice in procuring the…

1Opinion of the Court

Sayers F. Harman, Petitioner, v. Commissioner of Internal Revenue, Respondent. C. Henry Harman, Petitioner, v. Commissioner of Internal Revenue, Respondent

Harman v. Commissioner

Docket Nos. 1145, 1146

United States Tax Court

4 T.C. 335; 1944 U.S. Tax Ct. LEXIS 19;

November 24, 1944, Promulgated

Decisions will be entered under Rule 50.

1. Petitioners were devised undivided life interests in coal lands in West Virginia, under the law of which they became vested with legal title. The lands were, under the facts, not subject to payment of the testator's debts. Held, that loss sustained upon sale and…

Also in this document: Dissent.

2Cases cited9 opinions

  1. Helvering v. StuartSupreme Court of the United States · 1942
  2. Irwin v. GavitSupreme Court of the United States · 1925
  3. Harman v. CommissionerUnited States Tax Court · 1944
  4. Harris v. EskridgeWest Virginia Supreme Court · 1942
  5. Coville & Garber v. GilmanWest Virginia Supreme Court · 1878

4 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API