Cassatt v. Commissioner
United States Board of Tax Appeals
1. A partnership which was engaged in the brokerage business paid a large sum for cancellation of leases upon which it was lessee. At the time of cancellation certain amounts expended for leasehold improvements had not been amortized. Held, that the aggregate of the cost of canceling the leases and the unamortized improvements to the leaseholds is deductible in the year the leases were canceled.
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1. A partnership which was engaged in the brokerage business paid a large sum for cancellation of leases upon which it was lessee. At the time of cancellation certain amounts expended for leasehold improvements had not been amortized. Held, that the aggregate of the cost of canceling the leases and the unamortized improvements to the leaseholds is deductible in the year the leases were canceled. Denholm & McKay Co.,2 B.T.A. 444, followed. 2. The partnership entered into an agreement with another brokerage firm by which the partnership agreed to urge its customers to transfer their accounts to…
1Opinion of the Court
*407OPINION.
Arundell:
Petitioners argue that the total cost of canceling the leases was not deductible in the year of cancellation but should be spread over the 72%-month period during which the Pierce contract was effective. Similar treatment is also urged for the unamortized cost of certain improvements placed upon the relinquished leaseholds by petitioners. Respondent has treated the entire cost of terminating the leases as an expense deductible in 1935 and has accorded a similar treatment to the unamortized cost of the improvements.
This action appears correct. It has long been a rule that the…
2Cases cited4 opinions
- Burnet v. LoganSupreme Court of the United States · 1931
- Lucas v. North Texas Lumber Co.Supreme Court of the United States · 1930
- American National Co. v. United StatesSupreme Court of the United States · 1927
- United States v. American Can Co.Supreme Court of the United States · 1930
3Cited by12 opinions
- Cassatt v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- T.J. ENTERPRISES v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1993
- U.S. Bancorp v. CommissionerUnited States Tax Court · 1998
- Cooper Foundation v. O'MALLEYDistrict Court, D. Nebraska · 1954
- Stuart Co. v. CommissionerUnited States Tax Court · 1950
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