Fifth Avenue-14th Street Corp. v. United States

This is an action to recover capital stock taxes paid and alleged to have been wrongfully assessed against the plaintiff.

Plaintiff is a corporation with broad charter powers, but its only activities were as stated below:

During the period involved, it owned and operated a sixteen-story loft building usually leased to about twenty-eight tenants for a term of one year for lofts and five years for stores. The building was managed by an agent who collected the rents from the tenants and paid and attended to everything in connection with the operation of the building, remitting to plaintiff the net…