Borland v. Commissioner
United States Board of Tax Appeals
1. The amount paid by petitioners in 1923 as consideration for the cancellation of a lease on property owned by them, held not a business expense deductible entirely from income for the year in which paid, but a capital expenditure, recoverable through deductions prorated over the unexpired term of the canceled lease contract. 2. Held, the cost of permanent partitions installed during 1923 in the Borland Building, which did not increase the value of the building as a whole,…
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1. The amount paid by petitioners in 1923 as consideration for the cancellation of a lease on property owned by them, held not a business expense deductible entirely from income for the year in which paid, but a capital expenditure, recoverable through deductions prorated over the unexpired term of the canceled lease contract. 2. Held, the cost of permanent partitions installed during 1923 in the Borland Building, which did not increase the value of the building as a whole, did not constitute an ordinary business expense deductible in its entirety from income of said year, but was a capital…
1Opinion of the Court
HARRIET B. BORLAND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
CHAUNCEY B. BORLAND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
BRUCE BORLAND, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Borland v. Commissioner
Docket Nos. 31288, 31289, 31290.
United States Board of Tax Appeals
27 B.T.A. 538; 1933 BTA LEXIS 1349;
January 9, 1933, Promulgated
1. The amount paid by petitioners in 1923 as consideration for the cancellation of a lease on property owned by them, held not a business expense deductible entirely from income for the year in which paid, but a…
2Cases cited7 opinions
- Higginbotham-Bailey-Logan Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Lovejoy v. CommissionerUnited States Board of Tax Appeals · 1930
- Miller v. CommissionerUnited States Board of Tax Appeals · 1928
- Bonwit Teller & Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Central Bank Block Ass'n v. CommissionerUnited States Board of Tax Appeals · 1930
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