Wolff v. Commissioner
United States Tax Court
Annual payments made out of current income from property, in lieu of defaulted annuity payable for purchased life estate therein, held to measure amount and time of deduction for exhaustion of acquired interest, notwithstanding that payments were required to and did continue to be made to vendor's estate after her death.
1Opinion of the Court
OPINION.
OppeR, Judge:
Had petitioner paid to her stepmother the purchase price of the latter’s life estate in a lump sum, the amount represented thereby would have constituted an investment in a capital asset, exhaustible and therefore recoverable through deduction over the life of the asset acquired, that is, the life expectancy of the stepmother. See Caroline T. Kissel, 15 B. T. A. 705; Estate of F. S. Bell, 46 B. T. A. 484; reversed, other grounds (C. C. A., 8th Cir.), 137 Fed. (2d) 454. But the peculiar facts here present lend an almost fantastic complication to this comparatively simple…
2Cases cited6 opinions
- Helvering v. HorstSupreme Court of the United States · 1940
- United States v. LudeySupreme Court of the United States · 1927
- Douglas v. WillcutsSupreme Court of the United States · 1935
- Eckert v. BurnetSupreme Court of the United States · 1931
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
1 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Bell v. Harrison. Bell v. United StatesCourt of Appeals for the Seventh Circuit · 1954
- Manufacturers Hanover Trust Co. v. CommissionerCourt of Appeals for the Second Circuit · 1970
- Penn v. CommissionerUnited States Tax Court · 1951
- Manufacturers Hanover Trust Co. v. Commissioner Of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- Bell v. HarrisonDistrict Court, N.D. Illinois · 1952
4 more not listed; retrieve them via the Exa API.