- -4
United States, 423 F.2d 1118, 1120 (9th Cir. 1970); Gordon v.
Commissioner, 85 T.C. 309, 322-323 (1985); Early v. Commissioner,
52 T.C. 560, 566 (1969) (noting that section 167(a)(2)1 provides
the authority for such a deduction), revd. on another issue 445
F.2d 166, 169 (5th Cir. 1971). However, section 2732 disallows
deductions for amortization of a life interest acquired by gift,
bequest, or inheritance.
1 SEC. 167. DEPRECIATION.
(a) General Rule.--There shall be allowed as a
depreciation reduction a reasonable allowance for the
exhaustion, wear and tear (including a reasonable allowance
for obsolescence)--
* * * * * * *
(2) of property held for the production of
income.
2 SEC. 273. HOLDERS OF LIFE OR TERMINABLE INTEREST.
Amounts paid under the laws of a State, the
District of Columbia, a possession of the United
States, or a foreign country as income to the holder of
a life or terminable interest acquired by gift,
bequest, or inheritance shall not be reduced or
diminished by any deduction for shrinkage (by whatever
name called) in the value of such interest due to the
lapse of time.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011