Frieda Bernstein v. Commissioner of Internal Revenue, and Three Other Consolidated Cases

The taxpayers here seek to avoid the deficiencies assessed against them for 1946 and 1947 income taxes by showing error in the disallowance of depreciation and amortization deductions claimed by them. They bought land in New York City subject to a long-term lease, upon which was a commercial office building erected by the tenant before their purchase. They seek deduction of the claimed value of this building prorated over the remaining term of the lease, and they also seek amortization of what they claim is the “premium” value of this favorable lease. But as the Tax Court found, 22 T.C. 1146,…