Galt v. Commissioner
United States Tax Court
1. Rental income of property owned by petitioner and leased by him for 20 years partially on a percentage arrangement, held taxable to petitioner notwithstanding that part of the percentage income was given to his sons for the full lease period as evidenced by a letter and lease terms covering payment to the sons. 2. Pursuant to concessions of the parties, gift tax liability of petitioner for 1946 determined. 3. Deduction of lawyer's fee for various services determined.
1Opinion of the Court
Arthur T. Galt, Petitioner, v. Commissioner of Internal Revenue, Respondent
Galt v. Commissioner
Docket Nos. 27844, 29528
United States Tax Court
19 T.C. 892; 1953 U.S. Tax Ct. LEXIS 232;
February 27, 1953, Promulgated
Decisions will be entered under Rule 50.
1. Rental income of property owned by petitioner and leased by him for 20 years partially on a percentage arrangement, held taxable to petitioner notwithstanding that part of the percentage income was given to his sons for the full lease period as evidenced by a letter and lease terms covering payment to the sons.
2. Pursuant to concessions of…
2Cases cited44 opinions
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Helvering v. HorstSupreme Court of the United States · 1940
- Commissioner v. TowerSupreme Court of the United States · 1946
- Burnet v. HarmelSupreme Court of the United States · 1932
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