Legal Opinion

Allen W. Hinkel Dry Goods Co. v. Commissioner

United States Board of Tax Appeals

Decided January 26, 1928No. Docket No. 9841PublishedCited by 3 opinions

A leasehold with four years to run from March 1, 1913, is not, in the circumstances of this proceeding, converted into a 14-year lease by reason of a conditional renewal clause therein.

1Opinion of the Court

OPINION.

Landson :

The petitioner having abandoned its allegation of error as to adjustments of invested capital, it remains only for the Board to determine, for amortization purposes, the value, if any, of the *229leasehold here involved at March 1, 1913. The record is clear that at the basic date such leasehold had a remaining life of only 4 years and 1 month. The petitioner contends that the renewal privilege in the original lease in effect extended the terms thereof for an additional 10 years and that the Board should find that whatever value there was in the lease at March 1, 1913, is…

2Cited by3 opinions

  1. Allen W. Hinkel Dry Goods Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  2. Poly Holding Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
  3. Poly Holding Corp. v. CommissionerUnited States Board of Tax Appeals · 1934

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