American Spring & Wire Specialty Co. v. Commissioner
United States Tax Court
Petitioner, in purchasing realty to expand its facilities, paid $10,000 to the lessee thereof for the cancellation of the lease so that petitioner could obtain immediate possession. Held, that this payment is a capital expenditure and hence neither deductible, nor amortizable over the remaining life of the lease.
1Opinion of the Court
American Spring & Wire Specialty Co. v. Commissioner.
American Spring & Wire Specialty Co. v. Commissioner
Docket No. 72374.
United States Tax Court
T.C. Memo 1961-26; 1961 Tax Ct. Memo LEXIS 322; 20 T.C.M. (CCH) 116; T.C.M. (RIA) 61026;
January 31, 1961
Petitioner, in purchasing realty to expand its facilities, paid $10,000 to the lessee thereof for the cancellation of the lease so that petitioner could obtain immediate possession. Held, that this payment is a capital expenditure and hence neither deductible, nor amortizable over the remaining life of the lease.
Rayford W. Lemley, Esq., for the…
2Cases cited5 opinions
- Miller v. CommissionerUnited States Board of Tax Appeals · 1928
- Helvering v. Manhattan Life Ins. Co.Court of Appeals for the Second Circuit · 1934
- Stewart Title Guaranty Co. v. CommissionerUnited States Tax Court · 1953
- Thalhimer Bros., Inc. v. CommissionerUnited States Tax Court · 1957
- Manhattan Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
3Cited by2 opinions
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