Crile v. Commissioner of Internal Revenue

HICKENLOOPER, Circuit Judge.

On June 16, 1923, George W. Crile was the owner of an undivided three-fourths interest in certain improved real estate in the city of Cleveland. On the date mentioned he received an offer from the East Sixty-Third Euclid Company in whieh that company offered “to pay the sum of $100,000 for the buildings” erected upon this property, and to enter into a perpetual lease of the lot or land upon which such buildings stood. The proposed lease did not purport to convey the buildings apart from the land or to permit their severance and removal at the will of the lessee,…