United States v. The Albertson Company, a Corporation

McLAUGHLIN, District Judge.

This appeal involves federal income and personal holding company taxes for the years 1944 and 1945. The facts are not in dispute.

The Albertson Company, appellee, hereinafter referred to as the taxpayer, is a California corporation with its principal place of business in Los Angeles. The taxpayer purchased certain parcels of real property during the years 1923 to 1928, subject to tax liens. In acquiring these parcels, the taxpayer had to pay additional costs, such as escrow fees, recording fees, lighting assessments, commissions, title policy fees, and improvement…