Miami Valley Broadcasting Corporation v. Commissioner of Internal Revenue

ORDER

Upon review and consideration of this second appeal from a decision of the Tax Court, 39 T.C.M. (CCH) 760 (1979), after a previous opinion reversing and remanding the case, 594 F.2d 556 (6th Cir. 1979), we again reverse and remand the case to the Tax Court with instructions that the Tax Court conclude the matter by determining the value of the leasehold interest in question using a discount rate of 11%.

We judicially notice that the prevailing interest rate at the time the present value of the leasehold interest in question is to be determined for tax purposes (1964) was approximately 6%.…