CRILE

v.

COMMISSIONER OF INTERNAL REVENUE

Citator

Cited By

• Gates v. Helvering, 69 F.2d 277 (8th Cir. 1934)
  …ng ended with it, and both reverted to the owners of the land. The situation presented is similar to that dealt with by the Circuit Court of Appeals of the Sixth Circuit in Crile v. Commissioner of Internal Revenue, 55 F.(2d) 804, certiorari denied 287 U. S. 600, 53 S. Ct. 7, 77 L. Ed. 600. The court in that ease held that a payment by a lessee purporting to be for buildings upon leased land constituted taxable income as a bonus paid for a leasehold ‘estate, as a consideration in the nature of rental. To th…
• Boyce v. The United States, 405 F.2d 526 (Ct. Cl. 1968)
  …ding Co. v. Commissioner of Internal Revenue, 135 F. 2d 47, 146 A.L.R. 993 (5th Cir. 1943); Commissioner of Internal Revenue v. Lyon, 97 F. 2d 70 (9th Cir. 1938); Crile v. Commissioner of Internal Revenue, 55 F. 2d 804 (6th Cir. 1932), cert. denied, 287 U.S. 600, 53 S.Ct. 7, 77 L.Ed. 523; and Treas. Reg. sec. 1.61-8 (b). The problem is one of classifying the payment based on the purpose for which it is made, and this is generally a factual question to be resolved by an examination of the lease provisions an…