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" ... In VIP’s Industries Inc. & Subsidiaries v. Commissioner, T.C. Memo 2013-357, the taxpayer owned a ground lease with respect to real property. The ground lease was originally entered into in 1993 with a nonrenewable and nonextendable lease with an original term of 33 years. In 1994, the taxpayer constructed a motel on the property at a cost of $2,509,398 and operated the motel until 2006. ... "