Bradford Hotel Operating Co. v. Commissioner
United States Tax Court
Petitioner leased real property for a 35-year term commencing January 1, 1947, expiring January 1, 1982. A deposit of $ 250,000 was made by the lessee with the petitioner, as security for the performance of its obligations under the lease, and the petitioner was given the right to commingle and use the deposit for its own purposes without interest. The deposit was to be returned upon the expiration of the lease.
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Petitioner leased real property for a 35-year term commencing January 1, 1947, expiring January 1, 1982. A deposit of $ 250,000 was made by the lessee with the petitioner, as security for the performance of its obligations under the lease, and the petitioner was given the right to commingle and use the deposit for its own purposes without interest. The deposit was to be returned upon the expiration of the lease. On September 14, 1949, the parties entered into an agreement for the termination of the lease on January 3, 1950, the agreement providing for the return on that date of $ 65,000 of…
1Opinion of the Court
Bradford Hotel Operating Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
Bradford Hotel Operating Co. v. Commissioner
Docket No. 51840
United States Tax Court
26 T.C. 454; 1956 U.S. Tax Ct. LEXIS 172;
June 6, 1956, Filed
Decision will be entered under Rule 50.
Petitioner leased real property for a 35-year term commencing January 1, 1947, expiring January 1, 1982. A deposit of $ 250,000 was made by the lessee with the petitioner, as security for the performance of its obligations under the lease, and the petitioner was given the right to commingle and use the deposit for its own…
Also in this document: Dissent.
2Cases cited18 opinions
- Chesapeake & Ohio Railway Co. v. KellySupreme Court of the United States · 1916
- Hollwedel v. Duffy-Mott Co., Inc.New York Court of Appeals · 1933
- Prime's PetitionSupreme Court of Pennsylvania · 1939
- Sutton v. GoodmanMassachusetts Supreme Judicial Court · 1907
- Warren Service Corp. v. Commissioner of Internal Rev.Court of Appeals for the Second Circuit · 1940
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