Fifteen Hundred Walnut Street Corp. v. Commissioner
United States Tax Court
Petitioner held to have realized rental income during 1948, 1949, and 1950 when it furnished occupancy to a sublessee pursuant to a previous agreement with its lessee, rather than in 1943 when petitioner executed and delivered a nonnegotiable instrument to its lessee and the lessee, in turn, satisfied a judgment outstanding against petitioner.
1Opinion of the Court
OPINION.
Withey, Judge:
Petitioner takes the position that the amounts of $33,177.10, $61,250.04, and $28,072.86 with which petitioner debited the “Note Payable — First National Bank” account on its books during 1948, 1949, and 1950, respectively, and which National credited as interest income on its books during those years, did not constitute income taxable to it for 1948,1949, and 1950. In support of its position, petitioner contends that such amounts constituted advance rental realized in 1943 when the judgment against it was satisfied and its note was executed and delivered to National,
Resp…
2Cases cited4 opinions
- Spring City Foundry Co. v. CommissionerSupreme Court of the United States · 1934
- Commissioner of Internal Revenue v. LyonCourt of Appeals for the Ninth Circuit · 1938
- Brown v. CommissionerUnited States Tax Court · 1954
- Frankenfield v. CommissionerUnited States Tax Court · 1952
3Cited by1 opinion
- Fifteen Hundred Walnut Street Corp. v. CommissionerUnited States Tax Court · 1955