Legal Opinion

Central Bank Block Ass'n v. Commissioner

United States Board of Tax Appeals

Decided May 28, 1930No. Docket No. 40984PublishedCited by 12 opinions

The total amount of commissions paid by petitioner to its agent for services in procuring a lease contract, whereby it leased its property for a period of 50 years, should be spread ratably over such period and not deducted as an expense in the years in which paid, notwithstanding petitioner was on a cash receipts and disbursements basis.

1Opinion of the Court

*1184OPINION.

Trammell:

In the year 1922 the petitioner, acting through an agent, entered into a contract whereby it leased its property for a period of 50 years at a stipulated annual rental, increasing with each 5-year period. As compensation for the services rendered in that connection, the petitioner agreed to pay to the agent total commissions of $21,118.67, which were paid in three installments as follows: $1,118.67 in 1922, and $10,000 in each of the year's 1923 and 1924. The lease contract became operative in 1925, that is to say, the 50-year period began to run in that year.

*1185The petitioner…

2Cited by12 opinions

  1. Johnsen v. CommissionerUnited States Tax Court · 1984
  2. Estate of Papson v. CommissionerUnited States Tax Court · 1979
  3. 550 Park Ave. Corp. v. CommissionerUnited States Board of Tax Appeals · 1930
  4. Borland v. CommissionerUnited States Board of Tax Appeals · 1933
  5. Bourg v. CommissionerUnited States Tax Court · 1961

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