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PEMBROKE v. HELVERING

No. 6056.

70 F.2d 850 (1934)

PEMBROKE v. HELVERING, Commissioner of Internal Revenue.

Court of Appeals of the District of Columbia.

Decided April 23, 1934.

Attorney(s) appearing for the Case

Allen H. Gardner, of Washington, D. C., for petitioner.

Sewall Key, J. P. Jackson, E. Barrett Prettyman, and John D. Kiley, all of Washington, D. C., for respondent.

Before MARTIN, Chief Justice, and ROBB, VAN ORSDEL, HITZ, and GRONER, Associate Justices.

MARTIN, Chief Justice.

This case involves income taxes for the year 1925. The decision of the Board of Tax Appeals is reported in 23 B. T. A. 1176.

It appears that Andrew J. Pembroke, the petitioner, was the owner of certain real estate located in the city of Columbus, Ohio, described as 82-90 North Front street, and that the property was held by him for investment. In 1925 Pembroke leased the property to a tenant for a term of 99 years in consideration of...

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