by the entirety* until the court approved the settlement agreement, nothing entitled the trustee to the debtor’s wife’s interest in those properties. Only by formal agreement and later ratification by the bankruptcy court did the trustee become entitled to legal ownership of such properties. Furthermore, as for the deposits made in 1995, the trustee contends that those entries simply represent dates after which he liquidated assets and deposited them into the trust account. He claims those dates in no way illustrate the date on which he gathered the underlying assets or the date on which he became legally entitled to them. Importantly, ownership was transferred in 1994, when the bankruptcy court approved the global settlement. See Davies v. Comm., 101 T.C. 282, 1993 WL 387155 (1993)(<HOLDING>). The allegations made by the government simply
recognizing that a lease providing for renewal at the termination of the lease did not require the lessee to exercise the option before the lease expired nor did it require renewal at the precise hour of termination but gave the lessee a reasonable time after the termination of the lease in which to make his election holding that the damage for tenancy at sufferance during the holdover period was the monthly rent under the lease versus the apartments fair market value because the lease contained a provision requiring lease payments beyond the lease term holding that the question of whether a bankruptcy trustee or a putative lessor was entitled to the proceeds of an equipment sale depended on whether a true lease was involved when the lease is intended as a security interest article 9 applies however a bona fide lease is not affected by article 9 holding that former employees of a brokerage firm who had a contractual right to a share of any commission received by the firm upon extension of a lease were not entitled to a share of the commission received when the landlord and tenant entered an amendment to the lease which extended the duration but also added new terms this was a new lease not an extension of the prior lease holding that transferring the legal right to sell lease encumber or prevent the sale lease or encumbrance of property is a deductible event