City Investing Co. v. Commissioner
United States Tax Court
Pursuant to a policy of liquidating its property holdings in Lower Manhattan, T corporation in 1950 transferred its fee simple interest in land under certain commercial property to Conn. corporation for $ 4 million. The fair market value of such land on the date of transfer was not in excess of $ 4 million.
Read the full summary
Pursuant to a policy of liquidating its property holdings in Lower Manhattan, T corporation in 1950 transferred its fee simple interest in land under certain commercial property to Conn. corporation for $ 4 million. The fair market value of such land on the date of transfer was not in excess of $ 4 million. Simultaneously, Conn. leased back the land to T for an original term of 21 years, subject to specified renewals, at an annual net rental of $ 180,000 which was at least equal to the fair annual net rental for the land at the time. Held that the sale of the land was bona fide and the loss…
1Opinion of the Court
City Investing Company and Subsidiaries, Petitioners, v. Commissioner of Internal Revenue, Respondent
City Investing Co. v. Commissioner
Docket No. 83591
United States Tax Court
38 T.C. 1; 1962 U.S. Tax Ct. LEXIS 162;
April 3, 1962, Filed
Decision will be entered for the petitioner.
Pursuant to a policy of liquidating its property holdings in Lower Manhattan, T corporation in 1950 transferred its fee simple interest in land under certain commercial property to Conn. corporation for $ 4 million. The fair market value of such land on the date of transfer was not in excess of $ 4 million.…
2Cases cited5 opinions
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Century Electric Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1951
- Jordan Marsh Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1959
- May Dep't Stores Co. v. CommissionerUnited States Tax Court · 1951
- City Investing Co. v. CommissionerUnited States Tax Court · 1962