Park Place, Inc. v. Commissioner
United States Tax Court
Petitioner is a cooperative housing corporation for purposes of sec. 216, I.R.C. 1954. It holds legal title to an apartment building and appurtenances for the convenience of its tenant-stockholders. The interests of the tenant-stockholders are defined by the articles of incorporation and bylaws and by "perpetual proprietary leases" which are granted to each tenant-stockholder.
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Petitioner is a cooperative housing corporation for purposes of sec. 216, I.R.C. 1954. It holds legal title to an apartment building and appurtenances for the convenience of its tenant-stockholders. The interests of the tenant-stockholders are defined by the articles of incorporation and bylaws and by "perpetual proprietary leases" which are granted to each tenant-stockholder. Held, petitioner has no depreciable interest in the building, etc., allocable to the perpetual proprietary leases, but petitioner may deduct the depreciation allocable to the one apartment leased to a nonstockholder;…
1Opinion of the Court
Teetjens, Judge:
The Commissioner determined deficiencies in the income tax of petitioner Park Place, Inc., for calendar years 1965 and 1966 in the amounts of $4,234.99 and $755.74, respectively, the entire amounts of which are in controversy.
Petitioner is a cooperative housing corporation organized under the laws of the State of Florida, and during the calendar years in question it timely filed corporate income tax returns with the office of the district director of internal revenue in Jacksonville, Fla.
In calendar year 1965 the Commissioner disallowed claimed deductions for depreciation of a…
2Cases cited17 opinions
- Weiss v. WeinerSupreme Court of the United States · 1929
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Helvering v. BlissSupreme Court of the United States · 1934
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
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3Cited by25 opinions
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- Zapara v. Comm'rUnited States Tax Court · 2006
- Concord Village, Inc. v. CommissionerUnited States Tax Court · 1975
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