Termicold Corp. v. United States

OPINION

ON DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT

PHILIP R. MILLER, Judge:

In this suit to recover federal income taxes paid for the taxable years 1973 through 1976, defendant moves for summary judgment that plaintiff, Termicold Corporation (Termicold), is not entitled to deductions it claims for expenditures incurred in connection with an employee recreational facility. For the reasons discussed below, defendant’s motion is granted.

I

On September 1, 1973, Termicold purchased a 36-foot twin diesel engine boat for $59,541 and a dingy for $626.1 From the date of purchase through the…