Park Place, Inc. v. Commissioner
United States Tax Court
Petitioner is a cooperative housing corporation for purposes of sec. 216, I.R.C. 1954. It holds legal title to an apartment building and appurtenances for the convenience of its tenant-stockholders. The interests of the tenant-stockholders are defined by the articles of incorporation and bylaws and by "perpetual proprietary leases" which are granted to each tenant-stockholder.
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Petitioner is a cooperative housing corporation for purposes of sec. 216, I.R.C. 1954. It holds legal title to an apartment building and appurtenances for the convenience of its tenant-stockholders. The interests of the tenant-stockholders are defined by the articles of incorporation and bylaws and by "perpetual proprietary leases" which are granted to each tenant-stockholder. Held, petitioner has no depreciable interest in the building, etc., allocable to the perpetual proprietary leases, but petitioner may deduct the depreciation allocable to the one apartment leased to a nonstockholder;…
1Opinion of the Court
Park Place, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Park Place, Inc. v. Commissioner
Docket No. 4688-68
United States Tax Court
57 T.C. 767; 1972 U.S. Tax Ct. LEXIS 165;
March 14, 1972, Filed
Decision will be entered under Rule 50.
Petitioner is a cooperative housing corporation for purposes of sec. 216, I.R.C. 1954. It holds legal title to an apartment building and appurtenances for the convenience of its tenant-stockholders. The interests of the tenant-stockholders are defined by the articles of incorporation and bylaws and by "perpetual proprietary leases" which are…
Also in this document: Dissent.
2Cases cited18 opinions
- Weiss v. WeinerSupreme Court of the United States · 1929
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Helvering v. BlissSupreme Court of the United States · 1934
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
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