S & H, Inc. v. Commissioner
United States Tax Court
Petitioner, which had been in the business of acquiring improved real estate and either leasing it or operating it, entered into an agreement with Griffin to build a warehouse according to Griffin's specifications on land owned by petitioner and, upon completion, to lease it to Griffin for a period of 20 years, at a rental equal to 1 percent of the construction cost per month, with an option, exercisable by Griffin after 15 years, to purchase the property for the balance of…
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Petitioner, which had been in the business of acquiring improved real estate and either leasing it or operating it, entered into an agreement with Griffin to build a warehouse according to Griffin's specifications on land owned by petitioner and, upon completion, to lease it to Griffin for a period of 20 years, at a rental equal to 1 percent of the construction cost per month, with an option, exercisable by Griffin after 15 years, to purchase the property for the balance of the rental payments due over the life of the lease. The parties stipulated that the agreement constituted a sale of the…
1Opinion of the Court
S & H, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
S & H, Inc. v. Commissioner
Docket No. 15997-79
United States Tax Court
78 T.C. 234; 1982 U.S. Tax Ct. LEXIS 137; 78 T.C. No. 17;
February 16, 1982, Filed
Decision will be entered under Rule 155.
Petitioner, which had been in the business of acquiring improved real estate and either leasing it or operating it, entered into an agreement with Griffin to build a warehouse according to Griffin's specifications on land owned by petitioner and, upon completion, to lease it to Griffin for a period of 20 years, at a rental equal to 1…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Malat v. RiddellSupreme Court of the United States · 1966
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Robertson v. United StatesSupreme Court of the United States · 1952
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