Minneapolis Syndicate v. Commissioner
United States Board of Tax Appeals
INVESTED CAPITAL - LEASE - INCOME. - Petitioner in 1906, by warranty deed, conveyed the title to a certain building. By indenture executed the same date and as part of the same transaction it leased for a term of years to the same interests land upon which the building stood. The lease provided that the building was to be kept in repair, insured for the benefit of the petitioner, and be returned to petitioner as its property at the termination of the lease.
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INVESTED CAPITAL - LEASE - INCOME. - Petitioner in 1906, by warranty deed, conveyed the title to a certain building. By indenture executed the same date and as part of the same transaction it leased for a term of years to the same interests land upon which the building stood. The lease provided that the building was to be kept in repair, insured for the benefit of the petitioner, and be returned to petitioner as its property at the termination of the lease. Held, that the ultimate beneficial interest surrendered by petitioner and received by the lessees under the transaction was no more than…
1Opinion of the Court
*1306OPINION.
Trttssell :
Upon audit of petitioner’s tax return for the year 1917 invested capital as shown by its books in the sum of $1,009,156.93 was reduced by the revenue agent to $451,100.23, resulting in the determination by respondent of $3,216.18 additional income and profits taxes. To this petitioner objected, claiming invested capital in addition to that determined. Upon consideration of this question respondent held that it was impossible to compute petitioner’s correct invested capital and accordingly determined its tax liability under section 210 of the Eevenue Act of October 3, 1917.…
2Cases cited7 opinions
- Lewis v. CurnuttSupreme Court of Iowa · 1906
- Jacobs v. All Persons, Etc.California Court of Appeal · 1909
- Uecker v. ZuercherCourt of Appeals of Texas · 1909
- Metropolitan Securities Co. v. LaddCourt of Appeals for the Second Circuit · 1909
- O'Neil v. CaplesIllinois Supreme Court · 1913
2 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Commissioner of Internal Revenue v. SaltonstallCourt of Appeals for the First Circuit · 1941
- Gates v. CommissionerUnited States Board of Tax Appeals · 1932
- Meiselman v. CommissionerUnited States Tax Court · 1961
- Minneapolis Syndicate v. CommissionerUnited States Board of Tax Appeals · 1928