Downtown Athletic Club of New York City, Inc. v. State Tax Commission

In October, 1947, the Downtown Athletic Club of New York City, Inc., being in possession of real and personal property on West Street entered into an agreement of purchase with the owner the General Realty and Utilities Corporation.

The gross purchase price was $2,050,000 of which $1,750,000 was for the real property. The contract gave the purchaser the right to possession of the real and personal property “ in the operation of its normal functions as a social and athletic club ’ ’ and to continue such occupation and use while it Avas not in default. The contract was not recorded.

The club…