Ericksen v. Commissioner
United States Tax Court
1. On July 30, 1959, petitioners and petitioner-husband's mother, as lessors, leased certain property for a term of 49 years for a total rental of $686,000 ($14,000 per year) $28,000 "payable on execution of this lease."
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1. On July 30, 1959, petitioners and petitioner-husband's mother, as lessors, leased certain property for a term of 49 years for a total rental of $686,000 ($14,000 per year) $28,000 "payable on execution of this lease." At about the same time the lessors entered into an "Agreement for Division of Rent" whereby it was agreed that as long as petitioner-husband's mother shall live, she was to receive $4,500 of the yearly rental and petitioners were to receive $9,500. On February 20, 1962, an "Amendment to Lease" was executed between the lessors and lessee, wherein it was agreed that $14,000 of…
1Opinion of the Court
George E. Ericksen and Agnete B. Ericksen v. Commissioner.
Ericksen v. Commissioner
Docket No. 3114-62.
United States Tax Court
T.C. Memo 1964-111; 1964 Tax Ct. Memo LEXIS 223; 23 T.C.M. (CCH) 643; T.C.M. (RIA) 64111;
April 27, 1964
1. On July 30, 1959, petitioners and petitioner-husband's mother, as lessors, leased certain property for a term of 49 years for a total rental of $686,000 ($14,000 per year) $28,000 "payable on execution of this lease." At about the same time the lessors entered into an "Agreement for Division of Rent" whereby it was agreed that as long as petitioner-husband's mother…
2Cases cited5 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949
- Gilken Corp. v. CommissionerUnited States Tax Court · 1948
- Hirsch Improvement Co. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1944
- De Golia v. CommissionerUnited States Board of Tax Appeals · 1939