Hillside Nat'l Bank v. Commissioner
United States Tax Court
Petitioner purchased two parcels of improved real estate adjacent to its bank with the intention of demolishing or removing two buildings thereon and using the land as a means of access to its parking lot. In 1956 it demolished one of the buildings and sold the other after moving it to an unimproved lot which it owned.
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Petitioner purchased two parcels of improved real estate adjacent to its bank with the intention of demolishing or removing two buildings thereon and using the land as a means of access to its parking lot. In 1956 it demolished one of the buildings and sold the other after moving it to an unimproved lot which it owned. Efforts of petitioner to secure permission from the zoning authorities to use the land as a corridor to its parking lot were unsuccessful and it still owns the land. In its 1956 return it took deductions for losses claimed to have been sustained in connection with the…
1Opinion of the Court
OPINION.
Rattm, Judge:
Respondent determined a deficiency in the income tax of petitioner for the year 1956 in the amount of $12,307.69. The question for decision is whether petitioner, which acquired two parcels of improved property for the purpose of providing access to its parking lot, is entitled to deduct losses claimed to have been sustained in 1956 as the result of the demolition of a building on one property and the removal and sale of a building on the other property. All of the facts have been stipulated.
Petitioner, a national bank, has its principal place of business at the comer of…
2Cases cited6 opinions
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- Lynchburg Nat'l Bank & Trust Co. v. CommissionerUnited States Tax Court · 1953
- Lynchburg Nat. Bank & Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Providence Journal Co. v. BroderickCourt of Appeals for the First Circuit · 1939
- Blumenfeld Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
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3Cited by20 opinions
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- J. B. N. Telephone Company, Inc. v. United StatesCourt of Appeals for the Tenth Circuit · 1981
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