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Income Tax Keyed to Graetz
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Hort v. Commissioner
Citation:313 U.S. 28 (1941)
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Petitioner acquired a lot and ten-story office building from his father in which a firm called Irving Trust Co. (“the Company”) was subletting. Starting in 1927, the Company signed a fifteen-year for the main floor of the building. In 1933, the Company negotiated with Petitioner to cancel the remaining years of the lease in consideration of a $140,000 payment. Petitioner did not report this payment in his income tax return for 1933 and the Commissioner of Internal Revenue asserted a deficiency.
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