Dunn v. Commissioner
United States Tax Court
Petitioner, who was engaged in the business of buying and selling grain and renting grain-storage facilities, constructed certain special-purpose grain warehouses. He claimed depreciation based on a 5-year useful life for one building and a 10-year useful life for two others because of anticipated obsolescence resulting from governmental policies with respect to agricultural production.
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Petitioner, who was engaged in the business of buying and selling grain and renting grain-storage facilities, constructed certain special-purpose grain warehouses. He claimed depreciation based on a 5-year useful life for one building and a 10-year useful life for two others because of anticipated obsolescence resulting from governmental policies with respect to agricultural production. Held: That respondent's determination of a 20-year useful life for such facilities is proper. Evidence does not establish anticipated economic obsolescence of buildings.
1Opinion of the Court
Dawson, Judge:
Respondent determined deficiencies in the income tax of petitioners for the years 1958 and 1959 in the respective amounts of $3,852.37 and $4,332.08. The only issue for decision is whether the petitioners are entitled to depreciation deductions on certain special-purpose grain-storage warehousés in excess of those determined by respondent because of claimed anticipated economic obsolescence.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and exhibits attached thereto are incorporated herein by this reference.
James D. Dunn and Jo Ann Dunn are…
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