Brockman Bldg. Corp. v. Commissioner
United States Tax Court
Petitioner, lessee of a building, subleased a part of that building to another corporation. The sublessee agreed to pay a fixed rental for its lease. By a separate agreement made with a trustee, the sublessee agreed to pay a percentage of its sales, over a certain amount, to the trustee for the benefit of certain persons and corporations, who were petitioner's stockholders and creditors.
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Petitioner, lessee of a building, subleased a part of that building to another corporation. The sublessee agreed to pay a fixed rental for its lease. By a separate agreement made with a trustee, the sublessee agreed to pay a percentage of its sales, over a certain amount, to the trustee for the benefit of certain persons and corporations, who were petitioner's stockholders and creditors. Held, the payments made to the trust by the sublessee were taxable to the petitioner as its income. United States v. Joliet & Chicago R. Co., 315 U.S. 44. Held, further, petitioner is not liable for additions…
1Opinion of the Court
Brockman Building Corporation, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Brockman Bldg. Corp. v. Commissioner
Docket No. 34866
United States Tax Court
21 T.C. 175; 1953 U.S. Tax Ct. LEXIS 34;
November 4, 1953, Promulgated
Decision will be entered under Rule 50.
Petitioner, lessee of a building, subleased a part of that building to another corporation. The sublessee agreed to pay a fixed rental for its lease. By a separate agreement made with a trustee, the sublessee agreed to pay a percentage of its sales, over a certain amount, to the trustee for the benefit of certain…
2Cases cited20 opinions
- Lucas v. EarlSupreme Court of the United States · 1930
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- United States v. Boston & Maine RailroadSupreme Court of the United States · 1929
- United States v. Joliet & Chicago RailroadSupreme Court of the United States · 1942
- Raybestos-Manhattan, Inc. v. United StatesSupreme Court of the United States · 1935
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