Legal Opinion
Cleveland Allerton Hotel v. Commissioner of Int. Rev.
Court of Appeals for the Sixth Circuit
Decided March 22, 1948No. 10558PublishedCited by 19 opinions
1Opinion of the Court
SIMONS, Circuit Judge.
The tax problem posed by the present appeal is one for the solution of which there is no precedent. It is clearly a case of first impression, and involves the question whether a lessee in possession, owning and operating a hotel 'building on leased premises, who purchases the fee from the lessor for a price greater than the value of the land, may allocate a portion of the purchase price to the purchase of the unexpired lease either by deducting the allocated portion as a business expense in the year of purchase or depreciate it over the term of the lease or the…
2Cases cited3 opinions
- Limericks, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1948
- Cassatt v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Appeal of Denholm & McKay Co.United States Board of Tax Appeals · 1925
3Cited by19 opinions
- Jones, Collector of Internal Revenue v. CorbynCourt of Appeals for the Tenth Circuit · 1950
- Commissioner of Internal Revenue v. Moore. Moore v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1953
- Millinery Center Building Corp. v. CommissionerSupreme Court of the United States · 1956
- Darlington-Hartsville Coca-Cola Bottling Company, Inc. v. United States of America, Spartanburg Coca-Cola Bottling Co. v. United StatesCourt of Appeals for the Fourth Circuit · 1968
- Millinery Center Building Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1955
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