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    <description>A 99-year lease of land and building was treated as a transfer of a capital asset because the lessee obtained effective enjoyment of the property for a substantial period, and the substance of the arrangement prevailed over its label. The allotment of fully paid-up shares to the partners was treated as consideration received by the firm for the lease. Short-term capital gains treatment was rejected; if capital gains were assessable, the character depended on the period of holding, with the assessment year and the proper long-term treatment left for fresh examination.</description>
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