BRYANT TRUST. v. COMMISSIONER

Docket No. 14508.

11 T.C. 374 (1948)

HARRIET M. BRYANT TRUST, DR. CARL BRYANT SCHUTZ, ET AL., TRUSTEES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 27, 1948.


Attorney(s) appearing for the Case

Roy C. Hormberg, Esq., and E. R. Morrison, Esq., for the petitioner.

George E. Gibson, Esq., for the respondent.


The Commissioner determined a deficiency of $95,812.92 in petitioner's income tax for 1941, in part by adding to income a profit from the sale of improved real estate on which petitioner had reported a loss. Petitioner assails the determined value of the property at the time of its acquisition by devise, which value constitutes its basis; the depreciation rate used in the adjustment of basis; and the allocation of sale proceeds between the land, which was a capital asset...

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