William Penn Hotel Co. v. Commissioner
United States Board of Tax Appeals
1. Value of a lease for invested capital and exhaustion purposes determined. 2. Subsequently part of the lease was sublet for a part of the remainder of the term in consideration of certain agreed annual rentals and a bonus payment of $19,182.07. Held, the bonus payment to petitioner was not a return of capital, but was income to it in the year when received. James M. Butler,19 B.T.A. 718; Douglas Properties, Inc.,21 B.T.A. 347, followed.
1Opinion of the Court
*569OPINION.
Black :
The evidence in this proceeding establishes that the agreement which Buchalter, Block, Bronstein and Karsh had with Georgia A. Barth, to lease from her the William Penn Hotel property in the city of Denver for a rental of $22,000 per annum for a period of ten years, had a fair market value at the time it was paid in to petitioner of at least $50,000. When the petitioner issued and delivered its capital stock of the par value of $49,996 in payment for the assignment of the lease, it acquired something of value for such payment which it is entitled to exhaust over the term of the…
2Cited by1 opinion
- William Penn Hotel Co. v. CommissionerUnited States Board of Tax Appeals · 1931