QUEENSBORO CORPORATION v. COMMISSIONER OF INTERNAL REV.

No. 142.

134 F.2d 942 (1943)

QUEENSBORO CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

April 7, 1943.


Attorney(s) appearing for the Case

William S. Siemon, of Jackson Heights, N. Y., for petitioner, the Queensboro Corporation.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and Robert N. Anderson, Sp. Assts. to Atty. Gen., for respondent, Commissioner of Internal Revenue.

Before L. HAND, AUGUSTUS N. HAND, and FRANK, Circuit Judges.


AUGUSTUS N. HAND, Circuit Judge.

The taxpayer, Queensboro Corporation, was organized under the laws of the State of New York and under its charter is authorized to buy and sell real property and to transact a general real estate agency and brokerage business.

In 1909 or 1910 the taxpayer purchased thirteen unimproved lots in Long Island City, known as the Plaza property. These lots were bought subject to an existing mortgage of $50,000, dated July 1, 1909...

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