Rowley United Pension Fund v. Commissioner
United States Tax Court
Petitioner, a tax-exempt organization, leased land to a company on Dec. 19, 1953. Pursuant to the lease, petitioner constructed a building on the land which was occupied by the company in November 1954. The 1953 lease included an option under which the company, after the expiration of the 10th lease year, could request that petitioner construct an addition to the original building. In 1964 petitioner at the company's request provided for construction of an addition.
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Petitioner, a tax-exempt organization, leased land to a company on Dec. 19, 1953. Pursuant to the lease, petitioner constructed a building on the land which was occupied by the company in November 1954. The 1953 lease included an option under which the company, after the expiration of the 10th lease year, could request that petitioner construct an addition to the original building. In 1964 petitioner at the company's request provided for construction of an addition. Held, the indebtedness incurred to construct the original building was exempt from treatment as business lease indebtedness…
1Opinion of the Court
Rowley United Pension Fund, Petitioner v. Commissioner of Internal Revenue, Respondent
Rowley United Pension Fund v. Commissioner
Docket No. 9011-73
United States Tax Court
64 T.C. 343; 1975 U.S. Tax Ct. LEXIS 137;
May 29, 1975, Filed
Decision will be entered under Rule 155.
Petitioner, a tax-exempt organization, leased land to a company on Dec. 19, 1953. Pursuant to the lease, petitioner constructed a building on the land which was occupied by the company in November 1954. The 1953 lease included an option under which the company, after the expiration of the 10th lease year, could request that…
2Cases cited2 opinions
- Rowley United Pension Fund v. CommissionerUnited States Tax Court · 1975
- Chamber of Commerce v. CommissionerUnited States Tax Court · 1961