Legal Opinion

Watson Land Co. v. Commissioner

United States Tax Court

Decided April 5, 1983No. Docket No. 9211-77Unpublished

P, the owner of a large, master-planned industrial park, leased most of its buildings to industrial tenants on a net, net, net basis. As a result of the lease provisions, if a component wears out during the term of a lease, it must be replaced by the lessee. Held: Respondent's determination of useful lives of building shells sustained.

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P, the owner of a large, master-planned industrial park, leased most of its buildings to industrial tenants on a net, net, net basis. As a result of the lease provisions, if a component wears out during the term of a lease, it must be replaced by the lessee. Held: Respondent's determination of useful lives of building shells sustained. Held further: P is not entitled to depreciation deductions respecting the entire cost of certain components over their physical useful lives, but rather over a longer period as contended by respondent. Held further: Useful lives of other components determined.…

1Opinion of the Court

WATSON LAND COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Watson Land Co. v. Commissioner

Docket No. 9211-77.

United States Tax Court

T.C. Memo 1983-187; 1983 Tax Ct. Memo LEXIS 601; 45 T.C.M. (CCH) 1206; T.C.M. (RIA) 83187;

April 5, 1983.

P, the owner of a large, master-planned industrial park, leased most of its buildings to industrial tenants on a net, net, net basis. As a result of the lease provisions, if a component wears out during the term of a lease, it must be replaced by the lessee.

Held: Respondent's determination of useful lives of building shells sustained.

Held…

2Cases cited23 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  4. Casey v. CommissionerUnited States Tax Court · 1962
  5. Dunn v. CommissionerUnited States Tax Court · 1964

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