Rowe v. Commissioner
United States Board of Tax Appeals
On March 1, 1913, the petitioner was the owner through agents of certain leases of oyster lands in Narragansett Bay. The leases ran for a term of 10 years. By custom the lesee had the right to indefinitely renew the lease. The petitioner had invested from $100 to $200 per acre in cleaning the lands covered by the leases for oyster culture.
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On March 1, 1913, the petitioner was the owner through agents of certain leases of oyster lands in Narragansett Bay. The leases ran for a term of 10 years. By custom the lesee had the right to indefinitely renew the lease. The petitioner had invested from $100 to $200 per acre in cleaning the lands covered by the leases for oyster culture. The March 1, 1913, value of the leases held by the petitioner through his agents was not less than $100 multiplied by the number of acres covered by the lease. After March 1, 1913, the lands became polluted with industrial wastes to such an extent that they…
1Opinion of the Court
*908OPINION.
Smith:
The only question presented by this proceeding is the right of the petitioner to deduct from gross income in his income-tax returns for the fiscal years ended June 30, 1921, and June 30, 1922, $5,625 and $65,489.07, respectively, on leases of oyster lands in Narragansett Bay canceled during the taxable years. The respondent has disallowed the deductions upon the grounds that the petitioner had no enforceable rights in the leases canceled and that no deductible losses can be allocated to the taxable years.
*909The Revenue Act of 1921 provides that an individual in making income-tax…
2Cases cited1 opinion
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
3Cited by5 opinions
- Super Food Services, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1969
- Boos v. CommissionerUnited States Board of Tax Appeals · 1934
- Maytag v. CommissionerUnited States Tax Court · 1959
- Maytag v. CommissionerUnited States Tax Court · 1959
- Rowe v. CommissionerUnited States Board of Tax Appeals · 1930