Legal Opinion

Chamber of Commerce v. Commissioner

United States Tax Court

Decided January 13, 1961No. Docket No. 71897Published

Petitioner, an organization exempt from tax under section 101(7), I.R.C. 1939, leased its building to Pyramid. The lease itself was for a term of 46 months and gave the lessee the right to make any improvements it chose.

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Petitioner, an organization exempt from tax under section 101(7), I.R.C. 1939, leased its building to Pyramid. The lease itself was for a term of 46 months and gave the lessee the right to make any improvements it chose. Under an "Escape and Penalty Clause Agreement" executed 3 days after the lease, the lessee could ask for a 59-month renewal at the end of the original lease and if the lessor refused, lessor thereby became obligated to pay for all the lessee's improvements at 100 per cent of their original cost. The lessee intended to and did make extensive improvements immediately upon…

1Opinion of the Court

Chamber of Commerce of Kansas City, Kansas, Petitioner, v. Commissioner of Internal Revenue, Respondent

Chamber of Commerce v. Commissioner

Docket No. 71897

United States Tax Court

35 T.C. 562; 1961 U.S. Tax Ct. LEXIS 251;

January 13, 1961, Filed

Decision will be entered for the respondent.

Petitioner, an organization exempt from tax under section 101(7), I.R.C. 1939, leased its building to Pyramid. The lease itself was for a term of 46 months and gave the lessee the right to make any improvements it chose. Under an "Escape and Penalty Clause Agreement" executed 3 days after the lease, the lessee…

2Cases cited3 opinions

  1. Eimer & Amend v. CommissionerUnited States Board of Tax Appeals · 1925
  2. Sylvan Mortgage Co. v. AstruckAppellate Division of the Supreme Court of the State of New York · 1923
  3. Chamber of Commerce v. CommissionerUnited States Tax Court · 1961

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