Blackstone Theatre Co. v. Commissioner
United States Tax Court
Petitioner in 1941 acquired real estate in Chicago improved with a theatre building, against which there were outstanding tax liens and penalties exceeding $ 120,000. It set up the cost of the property on its books by including therein the full amount of such liens and penalties in addition to the substantial cash amounts paid to its vendor.
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Petitioner in 1941 acquired real estate in Chicago improved with a theatre building, against which there were outstanding tax liens and penalties exceeding $ 120,000. It set up the cost of the property on its books by including therein the full amount of such liens and penalties in addition to the substantial cash amounts paid to its vendor. In 1946, upon the availability to it of new capital, it purchased, at public sale, the outstanding tax liens for approximately $ 50,000, plus other capital charges. Respondent reduced petitioner's basis for depreciation of the building for the years prior…
1Opinion of the Court
OPINION.
Kern, Judge:
Respondent determined deficiencies in income tax for the years 1942, 1943, and 1944 and in excess profits tax for 1943, in the following amounts:
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Petitioner claims an overpayment in income tax for 1943.
Because of certain concessions by petitioner1 and because the determination of petitioner’s net operating loss carry-back from 1945 has been reserved by the parties for Rule 50 computation, dependent upon the outcome of this proceeding, only one issue is presented — petitioner’s basis for purposes of depreciation during the years before us of a theatre building…
Also in this document: Dissent.
2Cases cited4 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- United States v. HendlerSupreme Court of the United States · 1938
- Weir Long Leaf Lumber Co. v. CommissionerUnited States Tax Court · 1947
- Maltine Co. v. CommissionerUnited States Tax Court · 1945
3Cited by49 opinions
- Brannen v. CommissionerUnited States Tax Court · 1982
- Siegel v. CommissionerUnited States Tax Court · 1982
- Mayerson v. CommissionerUnited States Tax Court · 1966
- Waddell v. CommissionerUnited States Tax Court · 1986
- Bolger v. CommissionerUnited States Tax Court · 1973
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