Taxpayer, a tenant in possession of premises under a lease, received a payment from the lessor to vacate and surrender the premises before the lease expired. The Tax Court decided that the payment was taxable only as a capital gain. On appeal, held, affirmed. Since the leasehold interest constituted property, its transfer by the lessee to the lessor was a sale of a capital asset under I.R.C., §117. Commissioner v. Golonsky, (3d Cir. 1952) 200 F. (2d) 72
Testator died in 1903, and the executors turned over the residue of his estate to themselves as test...
Petitioner\u27s land was condemned by the city of New York and as compensation he was awarded a cert...
Taxpayer, upon being informed that his tenant would not renew his lease unless he could be assured o...
Taxpayer, a tenant in possession of premises under a lease, received a payment from the lessor to va...
The lessor and the sublessee of a valuable piece of business property sought to remove the interveni...
Taxpayer had the exclusive right for a period of ten years to purchase all the coal mined by the ope...
In 1915, defendant leased a tract of land to X for ninety-nine years. The lease provided that the le...
Petitioner executed a written agreement with a contractor in 1954 whereby the contractor acquired th...
In 1864 the Joliet and Chicago Railroad Company made a perpetual lease without a defeasance clause o...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
Petitioner sold a farm owned over six months upon which was a growing but unmatured wheat crop. When...
Petitioners, from 1937 to 1940, received distributions from the liquidation of a corporation of whic...
Plaintiff corporation leased its entire railroad property under a long-term lease subject to termina...
Defendant, a lessee, covenanted to pay all taxes assessed against the property. After having been tr...
Petitioners had formed a corporation for the purpose of building and operating a housing project. Af...
Testator died in 1903, and the executors turned over the residue of his estate to themselves as test...
Petitioner\u27s land was condemned by the city of New York and as compensation he was awarded a cert...
Taxpayer, upon being informed that his tenant would not renew his lease unless he could be assured o...
Taxpayer, a tenant in possession of premises under a lease, received a payment from the lessor to va...
The lessor and the sublessee of a valuable piece of business property sought to remove the interveni...
Taxpayer had the exclusive right for a period of ten years to purchase all the coal mined by the ope...
In 1915, defendant leased a tract of land to X for ninety-nine years. The lease provided that the le...
Petitioner executed a written agreement with a contractor in 1954 whereby the contractor acquired th...
In 1864 the Joliet and Chicago Railroad Company made a perpetual lease without a defeasance clause o...
In 1936, a taxpayer sold his interest in a partnership the assets of which were mainly acquired subs...
Petitioner sold a farm owned over six months upon which was a growing but unmatured wheat crop. When...
Petitioners, from 1937 to 1940, received distributions from the liquidation of a corporation of whic...
Plaintiff corporation leased its entire railroad property under a long-term lease subject to termina...
Defendant, a lessee, covenanted to pay all taxes assessed against the property. After having been tr...
Petitioners had formed a corporation for the purpose of building and operating a housing project. Af...
Testator died in 1903, and the executors turned over the residue of his estate to themselves as test...
Petitioner\u27s land was condemned by the city of New York and as compensation he was awarded a cert...
Taxpayer, upon being informed that his tenant would not renew his lease unless he could be assured o...