Campbell v. Commissioner
United States Tax Court
1. In 1934 the taxpayer inherited an interest in a parcel of real estate which for many years prior to his father's death had been used by him as a private residence. The taxpayer owned a private residence of his own and at no time used the property which he had inherited as a private residence, nor did he at any time have any intention of so doing.
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1. In 1934 the taxpayer inherited an interest in a parcel of real estate which for many years prior to his father's death had been used by him as a private residence. The taxpayer owned a private residence of his own and at no time used the property which he had inherited as a private residence, nor did he at any time have any intention of so doing. Immediately after the property came to him by inheritance, he placed it with real estate agents for sale or rent, but up until the time of sale had been unable to rent it. Held, the transaction, in so far as the taxpayer was concerned, was one…
1Opinion of the Court
OPINION.
Black, Judge-.
The Commissioner has determined a deficiency of $6,194.01 in petitioners’ income tax for the year 1941. Two of the adjustments made by the Commissioner are not contested. The two adjustments which are contested are the disallowance by the Commissioner of a net long term loss of $2,434.13 and the disallowance of an ordinary loss from the sale of property of $9,028.14. The Commissioner explained these two adjustments in his deficiency notice as follows:
The alleged loss of $11,462.27 claimed on your return in connection with the sale of certain residential property acquired…
2Cases cited1 opinion
- Marx v. CommissionerUnited States Tax Court · 1945
3Cited by52 opinions
- Hazard v. CommissionerUnited States Tax Court · 1946
- Lagreide v. CommissionerUnited States Tax Court · 1954
- Hopkins v. CommissionerUnited States Tax Court · 1950
- Estate of Ferber v. CommissionerUnited States Tax Court · 1954
- Jamison v. CommissionerUnited States Tax Court · 1947
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