Legal Opinion

University Properties, Inc. v. Commissioner

United States Tax Court

Decided January 31, 1966No. Docket No. 3557-64PublishedCited by 39 opinions

Lump-sum payments of $ 80,000 in each of the years involved, paid pursuant to the terms of a supplemental lease agreement wherein additional property was added to the original lease between petitioner and the University of Washington, and which designated the payments as "additional rentals," held, not to be deductible in full in the years in which paid either as rental or ordinary and necessary business expenses.

1Opinion of the Court

OPINION

Deennen, Judge:

Respondent determined deficiencies in petitioner’s income taxes for its fiscal years ended October 31, 1961 and 1962, in the respective amounts of $40,114.29 and $38,573.53.

The issue for decision is wlietlier payments in the amounts of $80,000 made by petitioner to the board of regents of the University of Washington in each of the taxable years involved, pursuant to a supplemental lease agreement between the board of regents and petitioner dated February 5,1958, wherein such payments are referred to as “additional rentals,” are deductible in full in the year paid, as…

2Cases cited11 opinions

  1. Booth Newspapers, Inc. v. The United States. The Evening News Association v. The United StatesUnited States Court of Claims · 1962
  2. Commissioner of Internal Revenue v. The Bagley & Sewall Co.Court of Appeals for the Second Circuit · 1955
  3. Baton Coal Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1931
  4. Main & McKinney Bldg. Co., of Houston v. CommissionerCourt of Appeals for the Fifth Circuit · 1940
  5. John J. Grier Co., a Corporation v. United StatesCourt of Appeals for the Seventh Circuit · 1964

6 more not listed; retrieve them via the Exa API.

3Cited by39 opinions

  1. Sandor v. CommissionerUnited States Tax Court · 1974
  2. Seaman v. CommissionerUnited States Tax Court · 1985
  3. Keller v. CommissionerUnited States Tax Court · 1982
  4. Martin J. And Margaret M. Zaninovich and Vincent M. And Dorothy F. Zaninovich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  5. University Properties, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1967

34 more not listed; retrieve them via the Exa API.

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