Third National Bank in Nashville v. United States

This is an appeal from the decision of District Judge L. Clure Morton in favor of the taxpayer in an income tax refund case. We affirm.

The facts are undisputed. Following unsuccessful negotiations for an outright purchase, the Bank entered into a 25 year lease agreement covering property in downtown Nashville, Tennessee. The lease provided for annual payments of $5,000 during its term. The lessors had an option, during the first 24/2 years, to require the Bank to purchase the property for $75,000; the Bank had an option, during the last six months, to purchase the property for the same price.…