Opinion

Millinery Center Bldg. Corp. v. Commissioner

21 T.C. 817
1954 U.S. Tax Ct. LEXIS 284

Court: United States Tax Court
Filed: Feb 26, 1954
Status: Published
Author: Aeundellmurdockopfertietjensbaumbice
On the bench: Withey,Opper,Tietjens,Raum,Rice
Cited by: 9 cases
Authority: More cited than 10.2%

Reversed on other grounds by Millinery Center Building Corporation v. Commissioner of Internal Revenue, 221 F.2d 322 (1955)

The opinion

AeuNdell, Murdock, Opfer, TietjeNS, Baum, and Bice, JJ., dissenting : Some part of the purchase price should be allocated to the additional rights in the building acquired in the purchase, using the principle of Cohan v. Commissioner, 39 F. 2d 540 , if necessary. This additional cost of the building would then be recovered through depreciation.

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