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STATE-ADAMS CORPORATION v. COMMISSIONER

Docket No. 63473.

32 T.C. 365 (1959)

STATE-ADAMS CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 15, 1959.

Attorney(s) appearing for the Case

H. Gilmer Wells, Esq., and Albert C. Petite, Esq., for the petitioner.

William T. Holloran, Esq., and Paul D. Barker, Esq., for the respondent.

Respondent determined a deficiency in petitioner's Federal income and excess profits tax for the year 1951 in the sum of $88,558.18. Respondent explained this determination as follows:

It is held that the lease of property located at State and Adams Streets, Chicago, Illinois, under which, The Fair, an Illinois corporation, is the lessee, which was transferred to you by your stockholder in 1933 for a note of $2,700,000.00 with interest at 5% per annum, represents...

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