“A ground rent is an estate of inheritance in the rent while the owner of the land has an estate of inheritance in the land out of which the rent issues. Each is the owner of a fee simple estate. The one is incorporeal and the other corporeal.”  Irwin v. Bank of the United States, 1 Pa. 349 (1845).

“A ‘ground rent,’ being an estate of inheritance in the rent of lands, is a freehold estate, and is a right to and interest in the lands.”  McCammon v. Cooper, 69 Ohio St. 366 (1904).

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