Legal Opinion

Pittsburgh Hotels Co. v. Commissioner

Court of Appeals for the Third Circuit

Decided September 11, 1930No. 4291PublishedCited by 24 opinions

1Opinion of the Court

DAVIS, Circuit Judge.

The petitioner filed a consolidated income and profits tax return which included the income of its subsidiaries, among which was the William Penn Hotel Company, which operated the William Penn Hotel in Pittsburgh, Pa. In the returns, the petitioner claimed 3% per cent, depreciation for “exhaustion, wear and tear,” but the Commissioner on a reaudit allowed only 2 per cent., and the petitioner appealed to this court.

The parts of the building on which the 3% per cent, rate of depreciation is claimed consists of the foundations, framework, walls, roof, floors, trimming,…

2Cases cited5 opinions

  1. The ConquerorSupreme Court of the United States · 1897
  2. Head v. HargraveSupreme Court of the United States · 1882
  3. Boggs & Buhl v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1929
  4. Idaho Power Co. v. ThompsonDistrict Court, D. Idaho · 1927
  5. WS Bogle & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1928

3Cited by24 opinions

  1. John Factor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
  2. Lorenzo Alvary v. United StatesCourt of Appeals for the Second Circuit · 1962
  3. Bonwit Teller & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931
  4. Uncasville Mfg. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
  5. Frances M. Cullers v. Commissioner of Internal Revenue, C. H. Cullers v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1956

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