Legal Opinion

De Cou v. Commissioner

United States Tax Court

Decided July 27, 1994No. Docket No. 11226-91Published

Held, a loss sustained as a result of the abnormal retirement of a building from the taxpayer's business (caused by a casualty to or an extraordinary obsolescence of the building) and sustained prior to the demolition of the building is not treated as having been sustained "on account of" the demolition of the building, and such loss will not be disallowed under sec. 280B, I.R.C.

1Opinion of the Court

Charles H. De Cou and Martha M. De Cou, Petitioners v. Commissioner of Internal Revenue, Respondent

De Cou v. Commissioner

Docket No. 11226-91

United States Tax Court

103 T.C. 80; 1994 U.S. Tax Ct. LEXIS 46; 103 T.C. No. 6;

July 27, 1994, Filed

Decision will be entered for petitioners.

Held, a loss sustained as a result of the abnormal retirement of a building from the taxpayer's business (caused by a casualty to or an extraordinary obsolescence of the building) and sustained prior to the demolition of the building is not treated as having been sustained "on account of" the demolition of the…

2Cases cited12 opinions

  1. Crane v. CommissionerSupreme Court of the United States · 1947
  2. United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
  3. Heyn v. CommissionerUnited States Tax Court · 1966
  4. White v. CommissionerUnited States Tax Court · 1967
  5. Coors Porcelain Co. v. CommissionerUnited States Tax Court · 1969

7 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API