Legal Opinion
Herbert Kaufman v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided October 18, 1966No. 10483_1PublishedCited by 12 opinions
1Opinion of the Court
J. SPENCER BELL, Circuit Judge.
Petitioner is in the real estate business in Baltimore, Maryland. Real estate in Baltimore is frequently sold not in fee simple but by transfer of a leasehold interest under lease of the land for 99 years, renewable forever. See C. I. R. v. Simmers’ Estate, 231 F.2d 909 (4 Cir. 1956). These leases generally provide that they may be redeemed by the lessee at any time after five years from their creation upon capitalization of the annual rental at a rate of 6%. Some older leases are not redeemable. The practical effect is to create a mortgage of indefinite…
2Cases cited10 opinions
- Lesly Cohen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Bell v. Harrison. Bell v. United StatesCourt of Appeals for the Seventh Circuit · 1954
- Liftin v. CommissionerUnited States Tax Court · 1961
- Welsh Homes, Incorporated, and v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1960
- Starr v. Minister & Trustees of the Starr Methodist Protestant ChurchCourt of Appeals of Maryland · 1910
5 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- Seymour Silverman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1976
- Bow Herbert and Nancy Herbert v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1967
- Warren Jones Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Heritage Realty, Inc. v. Mayor of BaltimoreCourt of Appeals of Maryland · 1969
- Herbert Kaufman v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1971
7 more not listed; retrieve them via the Exa API.