Legal Opinion

Nowland Realty Co. v. Commissioner

United States Board of Tax Appeals

Decided November 30, 1929No. Docket No. 34298Published

1. Held that certain amounts constructively received as rental by the petitioner as lessor from its president as lessee pursuant to the terms of a written lease entered into between them constituted rent to the petitioner. 2. Upon the facts, the accounts of two businesses should not be consolidated.

1Opinion of the Court

NOWLAND REALTY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Nowland Realty Co. v. Commissioner

Docket No. 34298.

United States Board of Tax Appeals

18 B.T.A. 405; 1929 BTA LEXIS 2056;

November 30, 1929, Promulgated

1. Held that certain amounts constructively received as rental by the petitioner as lessor from its president as lessee pursuant to the terms of a written lease entered into between them constituted rent to the petitioner.

2. Upon the facts, the accounts of two businesses should not be consolidated.

Frank C. Olive, Esq., for the petitioner.

A. H. Fast, Esq., for the…

2Cases cited1 opinion

  1. Nowland Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1929

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