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PARK AND 46TH STREET CORPORATION v. COMMISSIONER

Docket No. 21121.

14 T.C. 588 (1950)

PARK AND 46TH STREET CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 14, 1950.

Attorney(s) appearing for the Case

Maurice Dekoven, Esq., for the petitioner.

Thomas R. Wickersham, Esq., and Aaron Resnik, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner denied the petitioner's applications for relief under section 722 for 1942, 1943, and 1944. The petitioner claims that it is entitled to relief under section 722 (b) (5). The facts have been stipulated.

The petitioner is a New York Corporation, organized in 1923. It operates an office building at 250 Park Avenue, New York City. The building, completed on or about May 1, 1925, was erected by the petitioner...

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