New Capital Hotel, Inc. v. Commissioner
United States Tax Court
28 T.C. 706 (1957)
New Capital Hotel, Inc. (New Capital) (plaintiff) owned hotel property which it leased out from January 1, 1950, to December 31, 1959. Under the terms of the lease, the lessee was to pay New Capital $30,000 each year. New Capital also required the lessee to pay the last year’s rent in advance. The lessee paid the $30,000 for 1959 during 1949. No restrictions were placed on New Capital’s use of the $30,000. Because New Capital is an accrual method taxpayer, it believed that the $30,000 was not taxable until 1959, when the income was actually earned. The Commissioner (defendant) disagreed and determined that the $30,000 was taxable income in 1949, the year in which it was received.
Rule of Law
Holding and Reasoning (Black, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 174,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.