Central Bank Block Ass'n v. Commissioner
United States Board of Tax Appeals
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
- Johnsen v. CommissionerUnited States Tax Court · 1984
- Estate of Papson v. CommissionerUnited States Tax Court · 1979
- 550 Park Ave. Corp. v. CommissionerUnited States Board of Tax Appeals · 1930
- Borland v. CommissionerUnited States Board of Tax Appeals · 1933
- Bourg v. CommissionerUnited States Tax Court · 1961
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