Stough v. Comm'r
United States Tax Court
Lessor (Ps) constructed a commercial building and entered into a 10-year lease with Lessee (L). The lease requires L to pay monthly rent to Ps, and the monthly rent is based on the amount of "project costs" Ps incurred in acquiring and developing the leased property.
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Lessor (Ps) constructed a commercial building and entered into a 10-year lease with Lessee (L). The lease requires L to pay monthly rent to Ps, and the monthly rent is based on the amount of "project costs" Ps incurred in acquiring and developing the leased property. The lease provides L with the unilateral option to make a one-time payment to Ps to reduce "project costs" to be used in the calculation of rent and thus reduce the amount of rent otherwise owed by L under the lease. In 2008 L elected to make a $1 million payment to Ps pursuant to the terms of the lease. R argues that the $1…
1Opinion of the Court
MICHAEL H. STOUGH AND BARBARA M. STOUGH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Stough v. Comm'r
Docket No. 8256-11
United States Tax Court
144 T.C. 306; 2015 U.S. Tax Ct. LEXIS 24; 144 T.C. No. 16;
June 2, 2015, Filed
Decision will be entered under Rule 155.
Lessor (Ps) constructed a commercial building and entered into a 10-year lease with Lessee (L). The lease requires L to pay monthly rent to Ps, and the monthly rent is based on the amount of "project costs" Ps incurred in acquiring and developing the leased property. The lease provides L with the unilateral option to make a…
2Cases cited12 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- United States v. BoyleSupreme Court of the United States · 1985
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Knudsen v. Comm'rUnited States Tax Court · 2008
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