Legal Opinion
Real Estate Investment Trust of America v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided July 28, 1964No. 6288PublishedCited by 4 opinions
1Opinion of the Court
HARTIGAN, Circuit Judge.
This is a petition for review of a decision of the Tax Court entered on October 21,1963. The petitioners are Real Estate Investment Trust of America and its seven trustees but for purposes of this appeal only the Trust will be referred to, and that as petitioner.
The facts have been stipulated. In 1948 Boston Chamber of Commerce Realty Trust (hereinafter Realty Trust) was in arrears to the Prudential Insurance Company in the amount of $3,500,-000 unpaid principal borrowed between 1922 and 1925 to finance Realty Trust’s erection of a downtown office building. The loans…
2Cases cited15 opinions
- Commissioner v. P. G. Lake, Inc.Supreme Court of the United States · 1958
- Hort v. CommissionerSupreme Court of the United States · 1941
- Commissioner of Internal Revenue v. CaulkinsCourt of Appeals for the Sixth Circuit · 1944
- Commissioner of Internal Revenue v. J. I. Morgan and Frances MorganCourt of Appeals for the Ninth Circuit · 1959
- Harry Rosen and Rose Rosen v. United StatesCourt of Appeals for the Third Circuit · 1961
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3Cited by4 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- United States v. Midland-Ross Corp.Supreme Court of the United States · 1965
- Hyman v. CommissionerUnited States Tax Court · 1987
- Altmann v. CommissionerUnited States Tax Court · 1968