McALLISTER, Circuit Judge.
Petitioner, a taxpayer owning, and having all its capital invested in buildings and equipment, consisting of a department store, hotel, garage, and a warehouse, leased its properties for 99 years, with a provision that the lease was renewable forever. The lessee covenanted to keep the property in good repair and to replace all or any part thereof whenever necessary. Respondent, Commissioner of Internal Revenue, disallowed deductions from...
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