16 B.T.A. 1145 | B.T.A. | 1929
Lead Opinion
The questions presented herein were considered and disposed of in Elmer J. Keitel, 15 B. T. A. 903, where we held that a terminable interest in property purchased in consideration of a promise to pay an annuity to the grantor represented a capital investment which should be exhausted over the life of the estate so acquired. In that case there was no proof of the value of the estate acquired and the deduction to which petitioner was entitled could not be determined.
In the instant case the contract of December 8, 1921, provided for the absolute sale and transfer by Charlotte S. Holmes of her life interest in the estate of her husband, which we have found to have had a value of at least $92,500, in consideration of a promise to pay her an annuity of $25,000,
Decision will Toe entered under Rule 50.