26 U.S.C. § 109
Improvements by lessee on lessor’s property
Gross income does not include income (other than rent) derived by a lessor of real property on the termination of a lease, representing the value of such property attributable to buildings erected or other improvements made by the lessee.
Notes of Decisions
Cited in 8
cases, 1955–2004 · leading case: Edward R. Burt v. Isthmus Development Company
Edward R. Burt v. Isthmus Development Company (1955)
“838 , 26 U.S.C.A. § 109 ), all of whose business other than the purchase of equipment in the United States is conducted in Mexico by arrangement with Petróleos Mexicanos, a branch of the Mexican Government; that all of its records are in Mexico and all of the individuals…”
A. P. Green Export Company v. United States (1960)
“798 , 838, 26 U.S.C.A. § 109 , and qualified for the special tax credit allowed such corporations under section 26 of the Code, 26 U.”
Frank v. International Canadian Corp. (1962)
“The district court concluded— (1) That having received all of its income from sales outside the United States and having derived all of its income from the conduct of an active trade or business, International qualified as a Western Hemisphere trade corporation under § 109 of…”
Commissioner of Internal Revenue v. Grace H. Cunningham, Eugene F. Cunningham and Grace H. Cunningham (1958)
“798 , now 1954 Code § 109, 26 U.S.C.A. § 109 , provides that “Income, other than rent, derived by a lessor of real property upon the termination of a lease, representing the value of such property attributable to buildings erected or other improvements made by the lessee” shall…”
Otis Elevator Company, a Maine Corporation v. The United States (1962)
“798 , 838, 26 U.S.C.A. § 109 , defines Western Hemisphere trade corporations as follows: “For the purposes of this chapter, the term ‘western hemisphere trade corporation’ means a domestic corporation all of whose business is done in any country or countries in North, Central,…”
Dzina v. United States (2004)
“” 26 U.S.C. § 109 . However, this portion of the Internal Revenue Code applies to leases and rental contracts, not to land sale contracts.”
Electrical Export Corporation v. United States (1961)
“This case concerns § 109 of the Internal Revenue Code of 1939, 26 U.S.C.A. § 109 . The plaintiff, Electrical Export Corporation, is a Delaware corporation with its office and principal place of business located in New York City.”
Electrical Export Corp. v. United States (1961)
“798 , 838, 26 U.S.C. § 109 (1952 Ed.) provides as follows: Sec.”
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