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COMMISSIONER OF INT. REV. v. PENN ATHLETIC CLUB BLDG.

No. 9834.

176 F.2d 939 (1949)

COMMISSIONER OF INTERNAL REVENUE v. PENN ATHLETIC CLUB BLDG. et al.

United States Court of Appeals Third Circuit.

Decided September 29, 1949.

Attorney(s) appearing for the Case

Sumner M. Redstone, Washington, D. C. (Theron Lamar Caudle, Assistant Attorney General, Ellis N. Slack, Lee A. Jackson, Special Assistants to Attorney General, on the brief), for petitioner.

Sanford D. Beecher, Philadelphia, Pa. (Duane, Morris & Heckscher, Philadelphia, Pa., on the brief), for respondent.

Before MARIS, GOODRICH and KALODNER, Circuit Judges.

KALODNER, Circuit Judge.

The principal issue presented by the Commissioner's petition to review the decision of the Tax Court is whether the taxpayer, Girard Trust Company ("Girard"), held the property here involved as an owner in fee or as a mortgagee in possession. If Girard held as an owner in fee, rents received were includable in its gross income. If it held as a mortgagee in possession, the rentals were, of course, simply a return of capital to be applied in...

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