Plaza Inv. Co. v. Commissioner
United States Tax Court
In 1939 petitioner leased one of its stores for a term of 10 years, paying a commission of $ 3,070.83 to a real estate broker for making the lease. It was amortizing this payment over the life of the lease. In December 1942 petitioner dissolved and distributed all of its assets in kind to its stockholders.
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In 1939 petitioner leased one of its stores for a term of 10 years, paying a commission of $ 3,070.83 to a real estate broker for making the lease. It was amortizing this payment over the life of the lease. In December 1942 petitioner dissolved and distributed all of its assets in kind to its stockholders. During 1942 petitioner paid to a tenant an amount in partial reimbursement of an expenditure incurred by the tenant for the installation of an air-conditioning unit in a store of the petitioner. On its tax return for 1942 petitioner deducted as ordinary and necessary business expenses (a)…
1Opinion of the Court
OPINION.
Leech, Judge:
This proceeding involves excess profits tax deficiencies for the years 1941 and 1942 in the respective amounts of $357.35 and $2,826.44. The issues are: (1) Whether petitioner, in the year 1942, is entitled to deduct the unamortized balance of leasing commissions upon its dissolution and distribution of all its assets in kind to its stockholders in that year, and (2) whether petitioner is entitled to deduct an amount paid to its lessee as partial reimbursement of the cost of installing an air-conditioning unit. All the facts have been stipulated and are so found. The…
2Cited by15 opinions
- Fort Howard Corp. v. CommissionerUnited States Tax Court · 1994
- Anover Realty Corp. v. CommissionerUnited States Tax Court · 1960
- Longview Hilton Hotel Co. v. CommissionerUnited States Tax Court · 1947
- Malmstedt v. CommissionerCourt of Appeals for the Fourth Circuit · 1978
- Wolan v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1950
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