Calcasieu Paper Co. v. Commissioner
United States Tax Court
In 1947, petitioner received a 10-year lease of a townsite with an option to buy during the seventh and eighth years of the lease. If the option were exercised, payments made after the sixth year of the lease were to be applied to the purchase price. Petitioner, in its 1947 income tax return, deducted the amount paid in that year under the lease as rent. Respondent disallowed the deduction on the ground that the agreement was not a lease but a sale.
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In 1947, petitioner received a 10-year lease of a townsite with an option to buy during the seventh and eighth years of the lease. If the option were exercised, payments made after the sixth year of the lease were to be applied to the purchase price. Petitioner, in its 1947 income tax return, deducted the amount paid in that year under the lease as rent. Respondent disallowed the deduction on the ground that the agreement was not a lease but a sale. Held, the agreement was a lease, and the deduction as rent is allowed. Held, further, the useful life of a power plant purchased by petitioner…
1Opinion of the Court
Calcasieu Paper Company, Inc. v. Commissioner.
Calcasieu Paper Co. v. Commissioner
Docket No. 33392.
United States Tax Court
1953 Tax Ct. Memo LEXIS 392; 12 T.C.M. (CCH) 74; T.C.M. (RIA) 53028;
January 30, 1953
In 1947, petitioner received a 10-year lease of a townsite with an option to buy during the seventh and eighth years of the lease. If the option were exercised, payments made after the sixth year of the lease were to be applied to the purchase price. Petitioner, in its 1947 income tax return, deducted the amount paid in that year under the lease as rent. Respondent disallowed the deduction…
2Cases cited7 opinions
- Mills v. CommissionerUnited States Tax Court · 1948
- Bowen v. CommissionerUnited States Tax Court · 1949
- Gilken Corp. v. CommissionerUnited States Tax Court · 1948
- Holeproof Hosiery Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Eaton v. CommissionerUnited States Tax Court · 1948
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