Income Tax Keyed to Lind
Metropolitan Bldg. Co. v. Commissioner
The University of Washington leased property it owned to Metropolitan Building Company, Petitioner. Petitioner subleased the property and the sublessee was to construct a hotel on the property. The rent was $25,000 per year. The Olympic Hotel was constructed on the property and the sublease was acquired by Olympic, Inc. Petitioner conveyed to the University of Washington its leasehold interest on the property where the Olympic Hotel was located. Olympic paid Petitioner $137,000 for the assignment and transfer. The University then leased the property to Olympic. The Commissioner contends the amount paid by Olympic is taxable as ordinary income. The Tax Court affirmed the Commissioner.
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