Currier v. Commissioner
United States Tax Court
Held, taxpayer did not have a depreciable interest in certain real property: Charles Bertram Currier, 7 T.C. 980 (1946), is not res judicata as to this proceeding, involving different taxable years, nor does it act as a collateral estoppel as to matters in this proceeding which were not actually presented and determined in the earlier suit. Commissioner v. Sunnen, 333 U.S. 591 (1948).
1Opinion of the Court
Tietjens, Judge:
The Commissioner determined deficiencies in income taxes of petitioners as follows:
Tear Deficiency
1946 _$570. 05
1947 _ 687.72
1948 _ 530.02
The question in this case is whether Catharine B. Currier had a de-preciable interest in a building during the years 1946,1947, and 1948.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation, including the supplemental stipulation, and the exhibits attached thereto are incorporated herein by this reference.
C. Bertram Currier and Catharine B. Currier, husband and wife, resided in Hanover, Mass., at the time…
2Cases cited15 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Rowan v. CommissionerUnited States Tax Court · 1954
- Commissioner of Internal Revenue v. Revere Land Co.Court of Appeals for the Third Circuit · 1948
10 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
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- Rudolph Inv. Corp. v. CommissionerUnited States Tax Court · 1972
- MCGRATH v. COMMISSIONERUnited States Tax Court · 2002
- Bolger v. CommissionerUnited States Tax Court · 1973
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