Legal Opinion

Challenger, Inc. v. Commissioner

United States Tax Court

Decided December 31, 1964No. Docket Nos. 88427, 90742-90746UnpublishedCited by 3 opinions

The Pub, Saratoga, and Waldorf leased slot machines to Challenger. All four were corporations owned by Graves. 1. Held: most of the slot machine lease payments are not deductible by Challenger as rent. Deductible amount determined.

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The Pub, Saratoga, and Waldorf leased slot machines to Challenger. All four were corporations owned by Graves. 1. Held: most of the slot machine lease payments are not deductible by Challenger as rent. Deductible amount determined. Sections 482, 162(a)(3), I.R.C. 1954. 2. Receipts by the Pub, Saratoga, and Waldorf of the disallowed "rent" payments do not, on the facts of this case, constitute taxable income to those corporations. 3. The Pub's surtax exemption properly disallowed under section 1551, I.R.C. 1954. 4. Revival of a dormant corporation does not constitute acquisition of control of…

1Opinion of the Court

The Challenger, Inc.1 v. Commissioner.

Challenger, Inc. v. Commissioner

Docket Nos. 88427, 90742-90746.

United States Tax Court

T.C. Memo 1964-338; 1964 Tax Ct. Memo LEXIS 1; 23 T.C.M. (CCH) 2096; T.C.M. (RIA) 64338;

December 31, 1964

The Pub, Saratoga, and Waldorf leased slot machines to Challenger. All four were corporations owned by Graves.

1. Held: most of the slot machine lease payments are not deductible by Challenger as rent. Deductible amount determined. Sections 482, 162(a)(3), I.R.C. 1954.

2. Receipts by the Pub, Saratoga, and Waldorf of the disallowed "rent" payments do not, on the facts…

2Cases cited64 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Helvering v. TaylorSupreme Court of the United States · 1935
  3. Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
  4. Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
  5. Ach v. CommissionerUnited States Tax Court · 1964

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

3Cited by3 opinions

  1. Schering Corp. v. CommissionerUnited States Tax Court · 1978
  2. Sparks Nugget, Inc. v. CommissionerUnited States Tax Court · 1970
  3. Schering Corp. v. CommissionerUnited States Tax Court · 1978

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