Legal Opinion

550 Park Ave. Corp. v. Commissioner

United States Board of Tax Appeals

Decided July 22, 1930No. Docket Nos. 33838, 34031-34034Published

1. The petitioner held to be affiliated with each other and with certain other corporations for 1922 and 1923. 2. Two of the petitioner corporations paid commissions to real estate brokers for securing tenants for apartments in buildings owned by them in 1922, 1923, and 1924, charged the amounts to expense, and deducted the same from gross income in their income-tax returns.

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1. The petitioner held to be affiliated with each other and with certain other corporations for 1922 and 1923. 2. Two of the petitioner corporations paid commissions to real estate brokers for securing tenants for apartments in buildings owned by them in 1922, 1923, and 1924, charged the amounts to expense, and deducted the same from gross income in their income-tax returns. The rental commissions thus paid were disallowed as deductions by the Commissioner who held that they constituted the cost of capital assets and should be charged off over the life of the assets. The petitioners kept…

1Opinion of the Court

550 PARK AVENUE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

920 HOLDING CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

1148 FIFTH AVENUE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

907 FIFTH AVENUE, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

950 PARK AVENUE CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

550 Park Ave. Corp. v. Commissioner

Docket Nos. 33838, 34031-34034.

United States Board of Tax Appeals

20 B.T.A. 288; 1930 BTA LEXIS 2155;

July 22, 1930, Promulgated

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2Cases cited3 opinions

  1. Bonwit Teller & Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  2. Central Bank Block Ass'n v. CommissionerUnited States Board of Tax Appeals · 1930
  3. 550 Park Ave. Corp. v. CommissionerUnited States Board of Tax Appeals · 1930

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