Home Sav. & Loan Co. v. Commissioner

During the years 1947 through 1951 petitioner, an Ohio building and loan association, was exempt from Federal income taxation by reason of being a domestic building and loan association within the meaning of section 101(4) of the 1939 Code. Under the Revenue Act of 1951 petitioner became, for years subsequent to 1951, taxable as a corporation. In 1956 petitioner received a rebate of Ohio State property taxes paid by it in and for the years 1947 through 1951. Held: Because of its exemption during the years 1947 through 1951 petitioner realized no economic gain nor tax benefit from the payment…