Steinert v. Commissioner of Internal Revenue

33 T.C. 447 (1959)

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Steinert v. Commissioner of Internal Revenue

United States Tax Court
33 T.C. 447 (1959)

DD

Facts

Lena Steinert (plaintiff) was married to Alexander Steinert. Alexander owned two properties in Massachusetts. After Alexander died, the properties were placed in a testamentary trust. The properties were later conveyed to the First National Bank of Boston (bank). But, pursuant to Massachusetts law, Lena had certain interests in the properties. Thus, Lena entered into an agreement with the bank. Under the agreement, the bank held title to the properties in fee simple, and Lena had a life estate in each of the properties. Lena paid the real estate taxes on the properties and claimed deductions for these payments in her income tax returns. The Internal Revenue Service (IRS) (defendant) determined that Lena was not permitted to deduct the real estate taxes. Lena challenged the IRS’s determination in the United States Tax Court.

Rule of Law

Issue

Holding and Reasoning (Raum, J.)

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