Legal Opinion

Dorothy C. Thorpe Glass Mfg. Corp. v. Commissioner

United States Tax Court

Decided November 26, 1968No. Docket No. 144-67Published

T corporation owned real estate which it leased to an affiliate and in which the affiliate conducted its business operations. In order to expand its plant the affiliate subsequently leased an adjoining building from an unrelated third party.

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T corporation owned real estate which it leased to an affiliate and in which the affiliate conducted its business operations. In order to expand its plant the affiliate subsequently leased an adjoining building from an unrelated third party. Thereafter, threats of "legal action" for violations of a municipal building code in respect of such adjoining building made it economically impractical to continue using that building, and the needs of T's affiliate required it to seek other space. The only feasible alternative was to construct a new plant elsewhere; and financing therefor was obtainable…

1Opinion of the Court

Dorothy C. Thorpe Glass Mfg. Corp., Petitioner v. Commissioner of Internal Revenue, Respondent

Dorothy C. Thorpe Glass Mfg. Corp. v. Commissioner

Docket No. 144-67

United States Tax Court

51 T.C. 300; 1968 U.S. Tax Ct. LEXIS 23;

November 26, 1968, Filed

Decision will be entered under Rule 50.

T corporation owned real estate which it leased to an affiliate and in which the affiliate conducted its business operations. In order to expand its plant the affiliate subsequently leased an adjoining building from an unrelated third party. Thereafter, threats of "legal action" for violations of a municipal…

2Cases cited12 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Vim Securities Corporation v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1942
  3. Dear Publication & Radio, Inc. v. CommissionerUnited States Tax Court · 1959
  4. Dear Publication & Radio, Inc., a New Jersey Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
  5. Masser v. CommissionerUnited States Tax Court · 1958

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