Legal Opinion

Daniel v. Commissioner

United States Tax Court

Decided July 24, 1978No. Docket No. 1580-75UnpublishedCited by 2 opinions

Petitioner leased certain improved real property for the purpose of running a restaurant. The lease was for a period of five years with an option to renew for another five-year period, plus an option to purchase the subject property at any time the lease was in effect. Petitioner derived a profit under the lease during the initial five-year term.

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Petitioner leased certain improved real property for the purpose of running a restaurant. The lease was for a period of five years with an option to renew for another five-year period, plus an option to purchase the subject property at any time the lease was in effect. Petitioner derived a profit under the lease during the initial five-year term. However, immediately prior to petitioner's exercise of his option to renew the lease for an additional five years, the restaurant operation closed. He never succeeded in getting the restaurant reopened and derived no income from the property during…

1Opinion of the Court

CLARENCE R. DANIEL and NANCY H. DANIEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Daniel v. Commissioner

Docket No. 1580-75.

United States Tax Court

T.C. Memo 1978-277; 1978 Tax Ct. Memo LEXIS 244; 37 T.C.M. (CCH) 1180; T.C.M. (RIA) 78277;

July 24, 1978, Filed

Petitioner leased certain improved real property for the purpose of running a restaurant. The lease was for a period of five years with an option to renew for another five-year period, plus an option to purchase the subject property at any time the lease was in effect. Petitioner derived a profit under the lease during the…

2Cases cited23 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Trust Under the Will of Bingham v. CommissionerSupreme Court of the United States · 1945
  3. Jasionowski v. CommissionerUnited States Tax Court · 1976
  4. Benz v. CommissionerUnited States Tax Court · 1974
  5. Boagni v. CommissionerUnited States Tax Court · 1973

18 more not listed; retrieve them via the Exa API.

3Cited by2 opinions

  1. Hoopengarner v. CommissionerUnited States Tax Court · 1983
  2. Hoopengarner v. CommissionerUnited States Tax Court · 1983

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