William Penn Hotel Co. v. Commissioner
United States Board of Tax Appeals
1. Value of a lease for invested capital and exhaustion purposes determined. 2. Subsequently part of the lease was sublet for a part of the remainder of the term in consideration of certain agreed annual rentals and a bonus payment of $19,182.07. Held, the bonus payment to petitioner was not a return of capital, but was income to it in the year when received. James M. Butler,19 B.T.A. 718; Douglas Properties, Inc.,21 B.T.A. 347, followed.
1Opinion of the Court
WILLIAM PENN HOTEL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
William Penn Hotel Co. v. Commissioner
Docket No. 24169.
United States Board of Tax Appeals
23 B.T.A. 566; 1931 BTA LEXIS 1852;
June 4, 1931, Promulgated
1. Value of a lease for invested capital and exhaustion purposes determined.
2. Subsequently part of the lease was sublet for a part of the remainder of the term in consideration of certain agreed annual rentals and a bonus payment of $19,182.07. Held, the bonus payment to petitioner was not a return of capital, but was income to it in the year when received.…
2Cases cited5 opinions
- Fall River Electric Light Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Butler v. CommissionerUnited States Board of Tax Appeals · 1930
- Alexander v. CommissionerUnited States Board of Tax Appeals · 1928
- Douglas Properties, Inc. v. CommissionerUnited States Board of Tax Appeals · 1930
- William Penn Hotel Co. v. CommissionerUnited States Board of Tax Appeals · 1931