Opinion

Home Trust Co. v. Commissioner

  • 21 B.T.A. 1255
  • 1931 BTA LEXIS 2229
Court
United States Board of Tax Appeals
Filed
Jan 19, 1931
Status
Published
Author
Sternhagen
On the bench
Lansdon, Phillips, Only, Trammell, Sternhagen
Cited by
2 cases

The opinion

SterNhageN,

dissenting: The petitioner bought stock in another corporation for $105,000, then advanced $75,000 to its subsidiary as a means of getting rid of the sublessee, and then dissolved the subsidiary. These are facts, each with its substantial legal significance ; and I can not agree that we may take the whole situation, ignore the clear facts, and say that the petitioner paid $180,000 for a 99-year lease.

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