PENN ATHLETIC CLUB BUILDING v. COMMISSIONER

Docket No. 9007.

10 T.C. 919 (1948)

PENN ATHLETIC CLUB BUILDING, GIRARD TRUST COMPANY, TRUSTEE FOR FIRST MORTGAGE BONDHOLDERS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 24, 1948.


Attorney(s) appearing for the Case

Sanford D. Beecher, Esq., for the petitioner.

Wm. D. Harris, Esq., for the respondent.


The respondent determined deficiencies in the income tax of petitioner in the amount of $106,328.43 for the calendar year 1942 and in the amount of $94,851.60 for the calendar year 1943.

The questions presented are:

(1) Is petitioner required to include in its gross income for the taxable years rents received by it during those years from the Penn Athletic Club Building?

(2) If it is held that the rent from the building is includible in petitioner...

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