Legal Opinion

Bellingham Cold Storage Co. v. Commissioner

United States Tax Court

Decided April 16, 1975No. Docket No. 9144-72Published

Petitioner leased improved properties on 50-year and 46-year, 11-month leases from the Port, a public agency which financed construction of the improvements through the sale of industrial development bonds.

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Petitioner leased improved properties on 50-year and 46-year, 11-month leases from the Port, a public agency which financed construction of the improvements through the sale of industrial development bonds. Under the 50-year lease, covering 12.75 acres, the monthly rental was $ 7,900 for the first 16 months, $ 7,500 for the next 17 years, 5 months, $ 4,750 for the next 4 years and 2 months, and thereafter was to be renegotiated at a rate not less than the Port's then average ground rent for other tenants. Under the 46-year, 11-month lease, covering 1.96 acres, the rent was $ 4,500 for 30…

1Opinion of the Court

Bellingham Cold Storage Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Bellingham Cold Storage Co. v. Commissioner

Docket No. 9144-72

United States Tax Court

64 T.C. 51; 1975 U.S. Tax Ct. LEXIS 163;

April 16, 1975, Filed

Decision will be entered under Rule 155.

Petitioner leased improved properties on 50-year and 46-year, 11-month leases from the Port, a public agency which financed construction of the improvements through the sale of industrial development bonds. Under the 50-year lease, covering 12.75 acres, the monthly rental was $ 7,900 for the first 16 months, $ 7,500 for…

2Cases cited14 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. American Metal Products Corporation v. Commissioner of Internal Revenue, Adler Metal Products Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
  3. American Metal Products Corp. v. CommissionerUnited States Tax Court · 1960
  4. Southern Ford Tractor Corp. v. CommissionerUnited States Tax Court · 1958
  5. Baton Coal Co. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1931

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