Estate of Skouras v. Commissioner
United States Tax Court
1. C, lessee under a long-term lease, subleases to I, which in turn subleases to R. B contracts to manage the property for R. C and I are wholly-owned subsidiaries of U while R is owned equally by U and B. After almost two decades of mutually-arranged amendments and extensions of the subleases and the management contracts, C sells its remaining leasehold interest to D for a small fraction of its then fair market value.
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1. C, lessee under a long-term lease, subleases to I, which in turn subleases to R. B contracts to manage the property for R. C and I are wholly-owned subsidiaries of U while R is owned equally by U and B. After almost two decades of mutually-arranged amendments and extensions of the subleases and the management contracts, C sells its remaining leasehold interest to D for a small fraction of its then fair market value. D, also, is owned equally by U and B. Held: Respondent sustained in disallowing C's deduction of the difference between its basis in the leasehold and what it received on the…
1Opinion of the Court
Estate of Charles P. Skouras, Deceased, Charles P. Skouras, Jr., George P. Skouras, Spyros P. Skouras and John B. Bertero, Executors, et al. 1 v. Commissioner.
Estate of Skouras v. Commissioner
Docket Nos. 74929-74934.
United States Tax Court
T.C. Memo 1962-33; 1962 Tax Ct. Memo LEXIS 271; 21 T.C.M. (CCH) 152; T.C.M. (RIA) 62033;
February 23, 1962
1. C, lessee under a long-term lease, subleases to I, which in turn subleases to R. B contracts to manage the property for R. C and I are wholly-owned subsidiaries of U while R is owned equally by U and B. After almost two decades of mutually-arranged…
2Cases cited24 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. TaylorSupreme Court of the United States · 1935
- Higgins v. SmithSupreme Court of the United States · 1940
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- United States v. MantonCourt of Appeals for the Second Circuit · 1938
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