Smith v. Commissioner
United States Tax Court
1. Petitioners in late 1959 entered into an agreement to purchase a business and sublease the property on which the business was conducted, the agreement specifically providing that petitioners would by June 1, 1962, exercise the option to purchase the property contained in the lease which petitioners acquired, which lease provided for 40 percent of rental payments being credited towards the purchase price of the property.
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1. Petitioners in late 1959 entered into an agreement to purchase a business and sublease the property on which the business was conducted, the agreement specifically providing that petitioners would by June 1, 1962, exercise the option to purchase the property contained in the lease which petitioners acquired, which lease provided for 40 percent of rental payments being credited towards the purchase price of the property. Petitioners leased another property under a 5-year lease with an option to purchase that property, which lease provided that if the option were exercised, 25 percent of the…
1Opinion of the Court
Norman Baker Smith and Barbara Anne Smith, Petitioners v. Commissioner of Internal Revenue, Respondent
Smith v. Commissioner
Docket No. 4412-66
United States Tax Court
51 T.C. 429; 1968 U.S. Tax Ct. LEXIS 12;
December 18, 1968, Filed
Decision will be entered under Rule 50.
1. Petitioners in late 1959 entered into an agreement to purchase a business and sublease the property on which the business was conducted, the agreement specifically providing that petitioners would by June 1, 1962, exercise the option to purchase the property contained in the lease which petitioners acquired, which lease…
2Cases cited12 opinions
- Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- 2554-58 Creston Corp. v. CommissionerUnited States Tax Court · 1963
- University Properties, Inc. v. CommissionerUnited States Tax Court · 1966
- Martin v. CommissionerUnited States Tax Court · 1965
- University Properties, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1967
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