Brown Printing Company v. Commissioner of Internal Revenue

TUTTLE, Circuit Judge.

This petition for review of a decision of the Tax Court challenges the disallowance of part of the sums deducted by the taxpayer as rent paid to a trustee landlord under a lease executed between the parties who admittedly did not deal at arm’s length.

The lease in question was entered into in 1949, as a ten year extension of the original four year lease made in 1945 to run from May 1, 1945. The stock of petitioner was owned by trustees who also owned the building in question. Taxpayer states in its brief: “Petitioner has always admitted that these two parties could not…