Commissioner of Internal Revenue v. Hills Corp.

PHILLIPS, Circuit Judge.

This is a petition to review a decision of the Board of Tax Appeals.

The facts as found by the Board are these: On February 8, 1908, Lewis S. Hills and Theresa B. Hills, his wife, were the owners, as joint tenants, of a lot and certain improvements thereon situated in Salt Lake City, Utah. On the date above mentioned, they leased the lot to Callaway, Hoock & Francis, a Utah corporation, for a term of fifty years, commencing March 1, 1908. The lease reserved as rent, $250 per month during the first ten years of the term, $300 per month during the second ten years, $350…