Legal Opinion

719 Fifth Ave. Co. v. Commissioner

United States Board of Tax Appeals

Decided November 20, 1926No. Docket No. 6031PublishedCited by 7 opinions

The opinions of witnesses as to the value of a leasehold on March 1, 1913, considered and held to be not sufficiently well founded to prove value.

1Opinion of the Court

*567OPINION.

Sternhagbn:

In attempting to prove that on March 1, 1918, it owned a leasehold which had a net value of $300,000 over and above its obligations, the petitioner has offered the opinions of three witnesses. These opinions, considered in the light of the experience *568and reasoning upon which they are founded, may not safely be relied upon as establishing the price which a willing purchaser able to buy would pay for the leasehold in addition to the cost of the building and the current obligations fixed by the lease. Two of the witnesses had little or no qualifications to give weight to their…

2Cited by7 opinions

  1. Poly Holding Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. 719 Fifth Ave. Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  3. Bonwit Teller & Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  4. First Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Hotel De Soto Co. v. CommissionerUnited States Tax Court · 1945

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